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Home My WebLink About08-44040/ THIS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED. FOX and FOX By: CRAIG H.j FOX, ESQUIRE Attorney I.D. No. 49509 Attorneys For Plaintiff Suite 706, One Montgomery Plaza Airy and Swede Streets Norristown, PA; 19401 (610) 275-7990 AMERICAN G?NERAL FINANCIAL COURT OF COMMON PLEAS SERVICES, INIC. CUMBERLAND COUNTY, PA 600 N. Royal Avenue Evansville, IN 47715 V. NO.OF-???? C?r'vrl 77w MICHAEL HOLMES , 84 Deerfield Ro'd Camp Hill, PA ;17011 CIVIL ACTION COMPLAINT - CONTRACT j NOTICE TO DEFEND You have been sued in Court. If you wish to defend against the claims set forth in the following pages,; you must take action within twenty (20) days after this Complaint and Notice are served, by eritering a written appearance personally or by an attorney and filing in writing with the Court ypur defenses or objections to the claims set forth against you. You are warned that if you fail tp 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 for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 and (800) 990-9108 &\AMER-GEN\LARGE\$600-80 Complaint Note 0800708.DOC NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named inlthe attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you,, and mail it to you. If you do not dispute the debt, it is,'not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. FOX AND FOX /s/ Craig H. Fox, Esquire 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 GAAMER-GEMLARGE4600-80 Complaint Note 0800708.130C I THIS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED. FOX and FOX By: CRAIG H.I FOX, ESQUIRE Attorney I.D. No. 49509 Attorneys For Plaintiff Suite 706, One Montgomery Plaza Airy and Swede Streets Norristown, PA 19401 (610) 275-7990 AMERICAN G?INERAL FINANCIAL COURT OF COMMON PLEAS SERVICES, IN(. CUMBERLAND COUNTY, PA 600 N. Royal Avenue Evansville, IN ¢7715 V. NO. D d'? y y o l.?t?-? MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 CIVIL ACTION COMPLAINT - CONTRACT Plaintiff domes by its attorneys and complains against the Defendant upon a cause of action of which the following is a statement: 1. Tlie Plaintiff, American General Financial Services, Inc., is a business with an address located at 600 N. Royal Avenue, Evansville, IN 47715. 2. Defendant, Michael Holmes is an adult individual who resides at 84 Deerfield Road, Camp Hilli PA 17011. 3. Ori or about November 13, 2006, Defendant entered into a Home Improvement Installment Sale Contract. 4. Payment was financed through Plaintiff. True and correct copies of the Home Improvement Installment Sale Contract, Financing Agreements and other documents executed in G:AAMER-GEN\LARGE4600-80 Complaint Note 0800708.DOC i connection therewith are attached hereto collectively as Exhibit "A" and incorporated herein by reference, and ark collectively referred to herein as the "Contract". 5. Defendant is in default under the terms of the Contract because he has failed and refused, and continues to fail and refuse to make the payments required under the Contract. 6. P1irsuant to the terms of the Contract, Plaintiff is entitled to reasonable attorney's fees. 7. Pursuant to the terms of the Contract, and as a result of Defendant's failure to make the requireri payments when due, Plaintiff is entitled to a "late charge" of the lesser of 5% of the installment or $5.00. 8. Defendant has failed to cure the default as requested. Accordingly, and pursuant to the provisions of the Contract, Plaintiff declares all sums due under the Contract to be immediately due; and payable and Plaintiff requests judgment in the amount of the accelerated balance, together with the expenses of collection, including, but not limited to, reasonable attorneys' fees, cpsts and interest, in the following amounts: P#off Balance as of July 30, 2008: $10,512.43 R$asonable Attorney Fees: $ 3,000.00 Fi)ing Fee: $ 78.50 Sdrvice Costs: $ 100.00 Tgtal Due: $13,690.93 9. Interest through date of satisfaction of the judgment accrues at the per diem rate of $4.24. 10. Laie charges through date of satisfaction of the judgment accrue at the contract rate of $5.00 per month. GAAMER-GEMLARG0600-80 Complaint Note 0800708.DOC I? WHEREFORE, Plaintiff respectively requests the Court to enter judgment for Plaintiff and against De?endant, in the amount of $13,690.93 plus interest at the contract rate until satisfaction of the 'late charges, attorney fees and co judgment, y sts. G,I4. FOX. ley For Plaintiff GAAMER-GENTARGE\ 600- 80 Complaint Note 0800708.DOC 8124754537 2008-06- AMERICAN GENERAL FIN 06r1Y100rf 08:3 AM Sava: AGFRFRM/6 JIM 60'15167 P? w 1a 09:11:15 a.m. 07-07-2008 m i r WTI fig r AM ,$ po Is ?? 'Pitt, 4/10 EXHIBIT "A" 8124754537 07-07-2008 5/10 ap I I ? l t g ppgg Oppp ®t s ? 1 AMERIrAN GENERAL FIN 09:12:09 a.m. OJJJPW 08.30:31 AM Server AGFRFRMIa AD: WM497 9 GFS 09 Mich 71 97-2648 >*G18FRFRM16 misc. Ififf e tP ?pa P.? 00 8124754537 AMERICAN GENERAL FIN 09:13:01 a.m. 07-07-2008 30:31 AM Savor. AGWRM76 JIO: 5025497 psgo. 15 2008-06-23--09:19 AGFS 15 ech 717-697-2648 >>-AGFR P 7/18 a Contract Number: Q HCWE NPROV04ENT INSTALLMENT CONTRACT (FA) DATTE:! ll_ - SELLER: _ LICENSE NO.: BUYER: ADDRESS: +s Js?? t! ADDRESS: 40 r.er*erd=•err YM some to tbe• 0000 and/or swviaaa an Ow ISM dqa *W. Helow it aft in a or** >)de; ?a. gOrM 1p ?? •re Mtal amoraut M ttN IBM of their account egrowwd and twaft Ww t•Sokf or SaNst ateW,9" 41 ucur?ly Vrsat N tfls goods WWWO e=wd kk pall, =:: Kk?;; ' TL.t01F'40006 MW T" t70NE" :'lTZr.Li, ii3etrt:yi??yr+K!?TF•?'n ?.... •n:n %: :•:ti .,q.-r: TI* . hn the •ji2Mp • kwmence oOAng Ihat coven to worst io be PeMmed- ? Workmart'8•Compertaaron hta ywm C7 PubNc Loh* kimi noe or Seller N:qurYMNp.ae a ee?ktKSar, ¦ t"F,xw" OF AMOUW JAt l?sFl PRICIV $ Q. M .MTAX = O ;TOTAL S vy .•7.Y •f'"3'ji:d, ".`.:T? ty :4 "•Nr. ;:- : v •- •-: :: nn •.rf .M TOM FVW 0 Oh1?5;r aNAUDOW4 WCAMN.CO 16'11118 iM PMV W. The Wstn*n bft h omad. ara.:C W Pd" 1a??7.?aab Dtyens' rssrdaric? llWaO aDO?? pr ne 1Laowup aiwra es n dlil?er.nt rio?„ abors ftM lair' . sai?uuNO.tH6 WOO ,worse osr.rot begin unto an #w o. day rIOWW.*. ,. a. ousip At ?eMMlwq R. . PKbd alip! me. ` e2?Yen. an • of liil "a par'f1 'OWL 'OW ??y? `tINeI? Mn 66 PIT is oaN work a,;eoted ro .ran: ??? ai-? MN "Ma Oats wo* axpeated to be w" W& i ! g Nq?' tM ad Iaillr ?t¦i ?i V o _&W w;Seaer aw" to sign a contpietion . -? r ps• pe a& ...bold W r - - ?iNaai%M 1•rp Mi aM?ir?Mltr sr OUYFA"e ONOIIT7A YpU, 7HE BUYER, titlAY CANCEL 7'tNS 7q' ' Alff"A flYOq 70 mil lwamr OF'11i TMRDA?? M 711E OA7! OF TtIIS fAA[RZACT101w SEETHE A7TAQFIFD Nt7?t1CE OFC?1NCfE4 a4FYNttiAliAi1T. lWye Bat.low a oo* of d11e'1t m oVie trsinwi aomtra0t at the t4rNM ib ?W d%& d • r oe. AOMPWd ? Date 3ipna rod 8 r rne: 10 MOTICE: see reverse ewe ror Important addNiorW contract Nana. .-.+.ewrrnan MpV 6/10 8124754537 AMERICAN GENERAL FIN 09:14:00 a.m. 07-07-2008 30:31 AM Sewer, AOFRFRM18rJIM w2s4o? pop & 16 2008-06-23.09:19 .. AGFSp_ TER AN AGFR ?.?p.,? P 8/18 ` Personal lewdly, snd/MjUMp & do to seller ow oft tort" Wpt"es and not for oommerd d o other purPMM& P .: w and w,d?oc In U* *OOMW O ftdP s mud eerpoWab-tr pMar. or trtarid ??• Abwd ThO Prlos,gr!otvd hagllt s p? ? on s normal for such additronal? ? work and sM go OM 1' VM p arv auohIibee acnrNtione, SeNsrv oau 4M ? slydb aboft'oortdiON Is ark iytertirrpYNS. ,.rar vnh? paf?trtg Seltsr•Ibrwonc Wedgy pIn" omrsm Of to 4~. r ertonned pro S pR°'' BUWwwll?nbe" BNfsr7ki0biliNfAtl' Appm"panpPrfrptpsfsetorTe unlM alA RAW nobd on (+?01MffNfM,lf!? falls[ to obtain, at wok 3~ KPWW for ' suot M'or V49 be MY 001 ntet 10d h n r" wMh'q t"p'W. ? ?'1B in Pnxww or ?+ oompleyon tttetsol Buyer 8dNar abo ?° IPPORMOV. apPfrovftt3 or'piemNe aM in nraktng th? promlees eraeNa6iP I? irons' Mich r it Co"rprrwaao" and PWM'Ll@ldb agraft ktnxdnos in Much oo arrfounts ara?e etllter 3sNer 1o rnatntapf a n to . sew. ker,.Ny; an. oft d t'oould M" Uom V* work prNrt? done uridtrr?thfa ? kw or conb= obwfeanon wM .. ow d u ch all"Ift to w+tr clslr?R arldnp tram BeYsrb perbmsrnos or airy wont her"m and SOWOogon Of l.larra. ..., .. Other than SIV tien'or It MJW have m ion in smctwilY kftsned'crUM by Contact or wit of IeNf Bow &0 ?sto obMn ' aramoor»m'pI? w?alve4"n ol'al Ikrfs sera ;?ind'auboorftraCbr?i pffo?1o ?rtd•p?rta at ouch ?y 1lcrr0* one r antpl°ft gr h'+b00nhi'ator 11 esf p Nan kw?ol+MtQ w6fit pa tttad until rr l" oontnd, phy SdWdo" 9tMV MOnhe duo.' es aro requbW b release Buyer andRO t3uye?fs irtstparfce or A bond for ft purpose. "'x^04 from tlMllsr We* Ig ' Tic t aOpe7.W rt•tSoNsr wo" WW Vron 'rtandirds h a -ft Woik 'thN phcnirig8am ? rrfedfartira, tnab:it+ilrnen,'anli suboontraaoro In'tho foraanta oohrplNlon of . "lellrrTi?tleefeirr! 4Mr?s: vtlrsrrrle? noted o1i'#10 MM •lcM-tmnKN, Buy tiaidsnce upon ooMP"M of tffe work hemunder agrees to isnme an OOit pn debtla 1fofR ee•o.+gM,tPOW S alW' doo of 001M. "46 1 Cetrellt'Carr4iiiot3•If •tNitlotlrlir?C Od w oor?trsot dowitafts, -Such m rnwns OW be'toed kme w = i .eeefiE111Mt7EFt.'- , oa•v.,Asor P45l M qvq?„p ft" p%" .4--r'. ••• r wffl u mum", oluw rwyetrs) or Sewer mqy chows that any a, ' W ersy qu (a) ?? ry cIaIR10f dlMft between M it of Mb arb? tl n dauie?or a en*o bad w bye AftMen a ?) ?xrot elect to or MULft and ?p ?niff" ow Efts t vmvMd,•hawmw, them MWW can.ford to Moo"ovsk '' b ,mod oy vn and tl14 term4 of thp, ueglpr•.Ttfts p nbt bQ deenii?d:ad?rs?? °11'° p!°• tillhil?+t`uafer the Federal Rules of Evidence dnd National AftOm portan taode of Proadur? ttd Flee and limm of the Natlortat'Ar Ammon Fbrum may be 00 by g (800) 474.2371 ttBea 50191, ABmeepope, tirikfrfesola 56006. (861) d31 ( a -td??ouct atblk*09n on a class-wtoe nears. e? tM arbbratlor, III not be? . '?1tlfteE? yy atectin9 stbhayon stop Pail any i?riUal ov I that Seger shah heNll?sd by the tW1F. Seller agrees t0 P4Y the h19 saswble ratios place in the c6 arbbakA tip to sow IV" unhos Ill"Yera(a) are Of QOVWM by the Federal Adthdon Ad Judgmo t upon the award ; w ? ° ' I3tryer(s) agrees to the Art* anon tom tai' su disputes, atrne, or oonvofwrstw bstwean pre Provb n above; .7f 1A'F:AU 18 VOLUNTAt?y WAIvMI,D M e to be submmod b BINDING 4IMM TO A JUR1r YqM on S +!cf, subject b "Miry for tlquidoM the dole dam"* pmm*M v~ authortaed by L on the bu.ta.ae any 4y Ii wnan+ nopos of in co but if you resoled after flue AN. on the busl- trdtlQatlOn of damagea and to •purn any rights or action or `n?si0a Part'oflociiet~ere( h' ftw"on,-Buyer and. saw aproe 1W. this coritroct and any Addenda, Spod t don Sheets, sales , ! !u ?f cogtract arfP.4 M to. the Ngr? #dJOUf batotir. °he1f?'aOrM CREW 00NTRACT 18 SU Yk .•.._. SELLER OF 00008 On OBTARMM ALL CLAWS AND DEtM!( WIi1C f *. P RY WVDER BYTHE DF&MA SMALL NOT EXCEED URSUMAT I11D elf tNE 7/10 812475453,7 AMERICAN GENERAL FIN 09:14:44 a.m. 07-07-2008 8/10 008 08:30:31 AM SMW. AOFRFRMI6 JIB: 802M7 18 2008-06-23 09:19 AGFS 09 Mech 717-697-2648 >WGFRFRMI6 P 9/18 COuftETION CERTMCATE FOR HOME IMPROVEMENTS DIRECT LOANS OR RETAIL CONTRACTS Name & Address of C omer(s) Name Addresses of Financing Instltution Ian EtKtPJLQ. -AF,AAeJ A hl ft'(1 *OR of ff-A type of Ttansaotio (mark one). Direct Loan Raw Contract Mom to You nW the dmft ? rtiy e this oertificate ! as a congUon of credit approval. Do not son this certificate until mproveffmM In accordanoe with the terms ofyour oontmot or estos W"Mmt I (We) 000rerty t: (1) The credit as been used for property. Improvements In accordance with the contract or cost estimate fur- nished to th credMx with my (ouo credit application. p m nts have been completed In general aooordanoe with the oonUW or OOat estimate and (2) t-me o my (our) Irn __ iftow (3) 1 Me) ha not obtained and have not received any cash payment, rebate, cash bonus, or sales commis- slon, or kV of value from the dealer or contractor as an inducement to enter kilo this vaneaction. (4)1(We) ui0fle and that the selection of the dealer or contractor and the acceptance of the materials used and the work rmed is my (our) responsibility, and that the creditor doe& not guarantee the quality or work- manship products or property Improvements. No le. Upon of is signed Completion Certificate, Creditor may perform a visual inspecdon of home impb mente In men of ? that irl MM le solely for the eredltor'a ugmm to ensure that the work oonlracied for haso sub- etantiAfiy perbrmed. It not represent or guarantee the quality or workmanship of cite products or home improvements. SigrWure of Customer() A D ad before signing) Signature ustomer(s) Date (read before signing) X X Nolke b ex: YOU must execute this certinoate as a for disbursement on any dealer-originated transacd dealer ho knowin?iy and mah"Wly submits false Info n to a loredor in connection with the origina- tion of transaction shall be subject to the im of chill money penalties. The undemigneO oerdfles that: (1) The property MPlbvernents are in accordance with the contract or cost estimate furnished to the customer(s) and all necesse building or other permits have boon obtained. v rn ins have been feted In genoroi accordance with the contract or cost es timate and (2) to epjw4hh*0 t done e and K ), fl mpbyees, suers. suppliers or others engaged In con- ectwork Qene obmine goods use a Or supplied stave been paid and waivers of ail liens or potential (3) The have not been given or promised any cash payments, rebate, cash bonus, or sales commis- sionIng of value as art inducement to enter Into this transaction. (4) Any ints paid by the undersigned dealer are from the dealer's own resources and have not been r@&rle c uslonter(s) or any oter party(S) TThe o! rted this oerdfivate after completion of the property Improvements. and all signatures on F1 this and Adc?pq Of DeaIerqr Contractor Title, Signatu and Date 3 ( a --:9, A..' 60dWIA4441 Phone Call (Dow, Initials.; Commoretg): if as Mao (I) ) (9) Lelbr Sent: Yes No ( COPY) Slprtature and Date 8124754537. AMERICAN GENERAL FIN 08:71:22 a.m. 07-17-2008 8 /8 VERIFICATION The undersigned is a reps acrtative of Plaintiff and hereby states that I am authorized to take this Verification on behalf of Plaintiff, and that the factual statements made herein are true and correct to ,the best of my knowledge, information and belief. The undersigned understands that the Amemants made herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn Unification to authorities. shl y H ges RCC Coll n Repres ntative - Legal DATE: G.MM4'R.CFNU.AR00460040 Cc-plaint NoW 090070$.IVC III reH soo/e00•a 9qe-1 seat-9li-Ol8 XQJ ! X014NOJI HdVJ:EO 9001-ti-inf e:006111d 0SUL94311' LI•WMzINA v J=NQS INd BZ:sz:ii, wool ULO c, J 177 w c o? THIS IS AN ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED. FOX and FOX By: CRAIG H. FOX, ESQUIRE Attorney I.D. NO. 49509 Suite 706, One Montgomery Plaza Airy and Swede Streets Norristown, PA 19401 (610) 275-7990 AMERICAN G NERAL FINANCIAL SERVICES, IN . 600 N. Royal A enue Evansville, IN 47715 V. MICHAEL H MES O 84 Deerfield Ro d Camp Hill, PA 117011 Attorneys For Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 4j- ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly eater my appearance on behalf of the Plaintiff in the above matter. FOX AND FOX By: ?I G:\AMER-GEMLARGE4600-80 Complaint Note 0800708.130C ?:? rv crN -,? i ??} ? y.`._,, s titi?8 SHERIFF'S RETURN - REGULAR CASE NO: 2008-04404 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN GENERAL FINANCIAL VS HOLMES MICHAEL MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOLMES MICHAEL the DEFENDANT at 0020:10 HOURS, on the 11th day of August , 2008 at 84 DEERFIELD ROAD CAMP HILL, PA 17011 MICHAEL HOLMES by handing to DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 13.00 Affidavit .00 Surcharge 10.00 00 41.00 Sworn and Subscibed to before me this day So Answers: r R. Thomas Kline 08/13/2008 FOX & FOX By: Deput Sheriff of A. D. G:\AMER-GEN\ILARGE\8600-80 D.JDG.DOC FOX AND FOX BY: CRAIG H. FOX Identification No. 49509 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 AMERICAN GENERAL FINANCIAL SERVICES, INC. 600 N. Royal Avenue Evansville, IN 47715 V. MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-4404 Civil Term Notice is given that a judgment by default in the above captioned matter has been entered against you on 2009. PROTHONOTARY If you have any questions concerning the above please contact: CRAIG H. FOX, ESQUIRE Attorney for Party Filing FOX AND FOX 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 FOX AND FOX By: Craig H. Fox, Esquire Attorney I.D. No. 49509 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 Attorney for Plaintiff AMERICAN GENERAL FINANCIAL SERVICES, INC. 600 N. Royal Avenue Evansville, IN 47715 V. MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-4404 Civil Term PRAECIPE FOR ENTRY OF JUDGMENT FOR FAILURE TO FILE AN ANSWER AND ASSESSMENT OF DAMAGES TO THE OFFICE OF THE PROTHONOTARY: Kindly enter judgment in favor of the plaintiff and against the Defendant, MICHAEL HOLMES in the above case for failure to file an Answer to Plaintiff's Complaint in the sum of in accordance with the assessment of damages below. Kindly: (1) assess the damages in the above matter against the defendant, MICHAEL HOMLES as follows: Payoff Balance as of July 28, 2009: $ 8,183.84 Reasonable Attorney Fees: $ 3,000.00 Filing Fee: $to be added Service Costs: $to be added Total Due: ?11.1g * Interest from July 29, 2009 through date of full repayment of the debt accrues at the contract rate. Late charges through date of satisfaction of the judgment accrue at the contract rate. I hereby certify that Defendant was served with a copy of Complaint by the Sheriff on August 11, 2008 evidenced by the Sheriff Return of Service form attached hereto and that a ten (10) day Notice of Intent to take Default was sent to the Defendant on July 14, 2009 via Certificate of Mailing. DATED: H. Att6rne;? for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2008-04404 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN GENERAL FINANCIAL VS HOLMES MICHAEL (? U MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HOLMES MICHAEL DEFENDANT was served upon the at 0020:10 HOURS, on the 11th day of August 2008 at 84 DEERFIELD ROAD CAMP HILL, PA 17011 wiT l7TTT T•'IT TTl?T ART'1 f1 DEFENDANT by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 13.00 Affidavit .00 _ r Surcharge 10.00 R. Thomas Kline .00 41.00 08/13/2008 FOX & FOX eell, Sworn and Subscibed to By: before me this day Deput Sheriff of A. D. EXHIBIT "A" F G:\AMER-GEN\LARGE\8600-80 10 DAY.NOT #2.DOC FOX AND FOX By: Craig H. Fox, Esquire Attorney I.D. No. 49509 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 AMERICAN GENERAL FINANCIAL SERVICES, INC. 600 N. Royal Avenue Evansville, IN 47715 V. MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-4404 Civil Term TO: Michael Holmes 84 Deerfield Road Camp Hill, PA 17011 DATE OF NOTICE: July 14, 2009 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 CAN NOT 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 EXHIBIT "B" 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 If you have any questions concerning this notice, please call: Craig H. Fox FOX AND FOX 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 ,;;7 Cr ig Fo squ +? S i mepar fee,eahere tempsor Caron ?Pol This CerllOcde of Mali rg This form maybe used Ear4?ame?,^t,.-. in 1.1- ` -TOY-ANI) FOX. FCraig H. Fox, Implialmov PITNEY BOWES 02 1A $ 01.15° 706 01"- IK 00433 09 JUL14 2009 MAILED OM ZlP,C5 .Q 1 To. Michael Holmes ''osbmrkH•r• 84 Deerfield Road Camp HIll, PA 17011 j?? ?? O l S t? PS Form 3817, Apra 2007 PSN 7530-02-000-9065 ?4 00 ?'?'D FOX AND FOX By: Craig H. Fox, Esquire Attorney I.D. #49509 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 AMERICAN GENERAL FINANCIAL SERVICES, INC. 600 N. Royal Avenue Evansville, IN 47715 COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 NO. 08-4404 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE Craig H. Fox, Esquire hereby verifies that he represents the Plaintiff in the above entitled case; that he is authorized to make this verification on behalf of the Plaintiff; that to the best of his knowledge, information and belief the above named Defendant is over 18 years of age; the address of Defendant is a listed in the caption of this pleading; the occupation of Defendant is unknown; and Defendant is not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldier's and the Sailor's Civil Relief Act of 1940 and the amendments thereto. Deponent further states that he understand that these statements are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Cr i . Fox 9 At ey for Plaint; /f Sworn to and subscribed before me this `day of ? 2009 ,4 / 4 - ;E/? otary Public N ARU1L. LOS& Nomisbown 8oro X? M ?Y Public Comrni?on FOX AND FOX By: Craig H. Fox, Esquire Attorney I.D. No. 49509 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 Attorney for Plaintiff AMERICAN GENERAL FINANCIAL SERVICES, INC. 600 N. Royal Avenue Evansville, IN 47715 V. MICHAEL HOLMES 84 Deerfield Road . Camp Hill, PA 17011 COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-4404 Civil Term CERTIFICATION The undersigned does hereby certify that Defendant was served with a copy of Complaint by the Sheriff on August 11, 2008 evidenced by the Sheriff Return of Service form attached hereto and that a ten (10) day Notice of Intent to take Default was sent to the Defendant on July 14, 2009 via Certificate of Mailing. Cra Att CAF THE-_ NO AUG -1 ? a 89`l? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: American General Financial Services, Inc. 600 N. Royal Avenue Evansville, IN 47715 V. Michael Holmes 84 Deerfield Road Camp Hill, PA 17011 and ? Confessed Judgment ®Other - Bank attachment /money judgment File No. 08-4404 Amount Due Jr It 1 103.9 V Interest ? /" 7. xi, o i f' Atty's Comm +i 6e eJ Costs 4` (?? •? TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of County, for debt, interest and costs, upon the following described property of the defendant (s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of IIIIPHITd County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Any and all bank accounts maintained by defendant with*Pennsylvania State Empl. Credit Union at 121 Strawberry Square, Harrisburg, PA 17101. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s) ? (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date Sr l lie l !L'? Signature: Print Name: Craig H. Fox, Esquire Address: 706 One Montgomery Plaza Norristown, PA 19401 Attorney for: Plaintiff Telephone: (610) 275-7990 Supreme Court ID No: 49509 0 OF VNosW 2!1119 AUG 17 PM 2= 17 CUMBQ?"?,D i"OUNTY PENNSYLVANIA *M.so All. 00 79-90 14 . oo a. so t(o0.50 PP P. Tri CBF - Po AT H *a.oo f)eGo • 50 I'L ce,7&qq ej4 (2a9 a73 A. U, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-4404 Civil CIVIL ACTION - LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due AMERICAN GENERAL FINANCIAL SERVICES, INC., Plaintiff (s) From MICHAEL HOLMES, 84 Deerfield Road, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: STATE EMPLOYEE CREDIT UNION, 121 Strawberry Square, Harrisburg, PA 17101 Any and all bank accounts maintained by defendant 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 $11,183.84 Interest from 7/29/09 - to be added Atty's Comm % - to be added Atty Paid $160.50 Plaintiff Paid Date: 8/17/09 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs to be added Got Long, Proll"kiary/ By: Deputy REQUESTING PARTY: Name CRAIG H. FOX, ESQUIRE Address: FOX AND FOX 706 ONE MONTGOMERY PLAZA NORRISTOWN, PA 19401 Attorney for: PLAINTIFF Telephone: 610-275-7990 Supreme Court ID No. 49509 FOX AND FOX BY: CRAIG H. FOX Identification No. 49509 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 Attorney for Plaintiff AMERICAN GENERAL FINANCIAL COURT OF COMMON PLEAS SERVICES, INC. CUMBERLAND COUNTY, PA 600 N. Royal Avenue Evansville, IN 47715 qS, V. NO. 08-4404 Civil Term MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 and PENNSYLVANIA STATE EMPLOYEES a CREDIT UNION 121 Strawberry Square Harrisburg, PA 17101, ,. `'' Garnishee rI,/ `( 46 } INTERROGATORIES TO GARNISHEE N To: Pennsylvania State Employees W Credit Union 121 Strawberry Square Harrisburg, PA 17101 You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to the Defendant on any negotiable or other written instrument, or did the Defendant claim that you owed the Defendant any money or were liable to the Defendant for any reason? If so, describe with specificity. ,t No. ,. e 0 r S G AMER-GENTARGE\8600-80 Interrogatories in Attachment to Gamishee.doc 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? If so, describe with specificity. Yes. See attached. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? If so, describe with specificity. No. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? If so, describe with specificity. No. G:\AMER-GEMLARGE\8600-80 Interrogatories in Attachment to Gamishee.doc 5. At any time before or after you were served did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? No. 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to the Defendant's direction or otherwise discharge any claim of the Defendant against you? If so, describe with specificity. No. 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. No. G:AAMER-GEN\LARGEA600-80 Interrogatories in Attachment to Garnishee.doc 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. §8123? If so, identify each account. No. 9. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title securities, notes, coupons, receivables, collateral, checking and/or savings, tax or other accounts or deposits in which the Defendant(s), had an interest? If so, identify which of the foregoing and describe, with specificity, the property or amount of funds in your possession. No. 10. How much is the value of any property in your possession belonging to the Defendant(s)? See attached. GAAMER-GEMLARGE18000-80 Interrogatories in Attachment to Gamishee.doc . a 11. Have you ever owed money to Defendant(s) or held any property belonging to Defendant(s)? If the answer is year, state when you either satisfied the debt or disposed of the property and in which manner, for what consideration, and to whom. No. 12. At the time you were served, did you have property of the Defendant(s), on deposit or otherwise in your possession other than that indicated in the preceding Interrogatories? If so, identify such in detail. No. FOX AND FOX By: G:AMER-GEN\LARGE\8600-80 Interrogatories in Attachment to Gamishee.doe AMERICAN GENERAL FINANCIAL SERVICES, INC., Plaintiff VS. MICHAEL HOLMES, Defendant and PA STATE EMPLOYEES CREDIT UNION, Garnishee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-4404 Civil Term No. 2009-CV-10543-NT ANSWERS TO INTERROGATORIES 2. Account # 9008033699 Michael A. Holmes S1 Regular Shares $ 9.70* S4 Checking $ 1,409.78 $ - 300.00** *$5.00 Membership Fee held in Regular Shares. **$300.00 Exempt from attachment under 42 Pa.C.S. 8123. CF THE 2009 SEA' 17 PH 12: ? 2 G'' _'4i? FOX AND FOX BY: CRAIG H. FOX Identification No. 49509 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 AMERICAN GENERAL FINANCIAL SERVICES, INC. 600 N. Royal Avenue Evansville, IN 47715 V. MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 and PENNSYLVANIA STATE EMPLOYEES: CREDIT UNION 121 Strawberry Square Harrisburg, PA 17101, Garnishee Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-4404 Civil Term PRAECIPE FOR JUDGMENT UPON ADMISSION TO THE PROTHONOTARY: Please enter judgment on admission in answer to Interrogatories against Garnishee, PENNSYLVANIA STATE EMPLOYEES CREDIT UNION in the total amount of $1,114.48. A copy of Garnishee's Response to Plaintiffs Interrogatories in Attachment are attached hereto and marked as Exhibit "A". FOX AND FOX By: 1. FOX, for Plaintiff GAAMER-GENTARGE\8600-80 judgment by admission 090918.DOC EXHIBIT "A" GAAMER-GEMLARGE\8600-80 judgment by admission 090918.DOC e I A FOX AND FOX BY: CRAIG H. FOX Identification No. 49509 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 AMERICAN GENERAL FINANCIAL SERVICES, INC. 600 N. Royal Avenue Evansville, IN 47715 v. MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 and PENNSYLVANIA STATE EMPLOYEES CREDIT UNION 121 Strawberry Square Harrisburg, PA 17101, Garnishee Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA a ooG Y a? y3. (\1T NO. 08-4404 Civil Term INTERROGATORIES TO GARNISHEE To: Pennsylvania State Employees Credit Union 121 Strawberry Square Harrisburg, PA 17101 N You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to the Defendant on any negotiable or other written instrument, or did the Defendant claim that you owed the Defendant any money or were liable to the Defendant for anv reason? If so, describe with specificity. G 'AMER-GEN\LARGE\8600-80 Interrogatories in Attachment to Gamishee.doc 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant? If so, describe with specificity. Yes. See attached. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest? If so, describe with specificity. No. 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? If so, describe with specificity. No. G:\AMC-R-GENTARGE\8600-80 Inten'ogatories in Attachment to Gamishec.doc 5. At any time before or after you were served did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? No. 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to the Defendant's direction or otherwise discharge any claim of the Defendant against you? If so, describe with specificity. No. 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. No. G AMt.R-GEN`LAR &A000-80 Interrogatories in Attaclnnent to Garnishee doc 8. If you are a bank or other financial institution, at the time .you were served or at any subsequent time did the Defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. §8123? If so, identify each account. No. 9. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title securities, notes, coupons, receivables, collateral, checking and/or savings, tax or other accounts or deposits in which the Defendant(s), had an interest? If so, identify which of the foregoing and describe, with specificity, the property or amount of funds in your possession. No. 10. How much is the value of any property in your possession belonging to the Defendant(s)? See attached. GAAMER-GEMLARGE18000-80 Intetrogatol'ies in Attachment to Gamishee.doc 11. Have you ever owed money to Defendant(s) or held any property belonging to Defendant(s)? If the answer is year, state when you either satisfied the debt or disposed of the property and in which manner, for what consideration, and to whom. No. 12. At the time you were served, did you have property of the Defendant(s), on deposit or otherwise in your possession other than that indicated in the preceding Interrogatories? If so, identify such in detail. No. FOX AND FOX By: G .AMER-GEN'A-ARGE',8600-80 Intenogatones in Attachment to Gantishee.doc AMERICAN GENERAL FINANCIAL SERVICES, INC., Plaintiff VS. MICHAEL HOLMES, Defendant and PA STATE EMPLOYEES CREDIT UNION, Garnishee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-4404 Civil Term No. 2009-CV-10543-NT ANSWERS TO INTERROGATORIES 2. Account # 9008033699 Michael A. Holmes S1 Regular Shares $ 9.70* S4 Checking $ 1,409.78 $ - 300.00** *$5.00 Membership Fee held in Regular Shares. **$300.00 Exempt from attachment under 42 Pa.C.S. 8123. PSECO G September 15, 2009 Craig H. Fox, Esquire FOX AND FOX 706 One Montgomery Plaza Norristown, PA 19401 Re: American General Financial Services, Inc. v. Michael Holmes Dear Mr. Fox: ern 1 7 2009 This letter follows our receipt of a writ of attachment from your office on our member(s) Michael A. Holmes. We attached funds in the amount of $1,114.48. This amount excludes a $5.00 membership fee in Regular Shares. This amount also excludes $300.00 exempt from attachment under 42 Pa.C.S. 8123. Enclosed are the answered interrogatories. Please let us know if you wish to garnish the funds or dissolve the attachment. Should you have any questions, you may contact me at (800) 237-7328, menu selection #6, extension 3117. Sincerely, Kathleen Weinstein Judgment Collector Enclosure Pennsylvania State Employees Credit Union Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 • 717.234.8484 • 800.237.7328 Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 • 717.777.2100 (TDD) • 800.472.1967 (TDD) psecu.com This credit union is federally insured by the National Credit Union Administration. Equal Opportunity Lender 'OF THE PRMONOTARY 2009 OCT -1 PM 3: 06 OLMY PENNS`YWAN A 0.00 P CIL? 801 J PENNSYLVANIA RULE OF CIVIL PROCEDURE 236 (REVISED) NOTICE AMERICAN GENERAL FINANCIAL SERVICES, INC. 600 N. Royal Avenue Evansville, IN 47715 V. MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 and PENNSYLVANIA STATE EMPLOYEES: CREDIT UNION 121 Strawberry Square Harrisburg, PA 17101, Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-4404 Civil Term Notice is given that a judgment on Court findings in the above-captioned matter has been entered against you on 021 !L 2009. PROTHONOTARY If you have any questions concerning the above, please contact: CRAIG H. FOX, ESQUIRE Attorney for Plaintiff FOX AND FOX 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 GAAMER-GEMLARGE\8600-80 judgment by admission 090918.DOC FOX AND FOX BY: CRAIG H. FOX Identification No. 49509 706 One Montgomery Plaza Norristown, PA 19401 (610) 275-7990 AMERICAN GENERAL FINANCIAL SERVICES, INC. 600 N. Royal Avenue Evansville, IN 47715 V. MICHAEL HOLMES 84 Deerfield Road Camp Hill, PA 17011 and PENNSYLVANIA STATE EMPLOYEES: CREDIT UNION 121 Strawberry Square Harrisburg, PA 17101, Garnishee Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-4404 Civil Term/ PRAECIPE TO MARK JUDGMENT SATISFIED AS TO PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, ONLY TO THE PROTHONOTARY: Kindly mark the judgment entered against the Pennsylvania State Employees Credit Union, only, as satisfied. By: FOX AND FOX Fox, Esquire for Plaintiff, GAAMER-GEN\LARGE18600-80 Praec to Mark Judgmt Satisfied (PSECU) 091022.doc H k3?G<<OTAR`( -)F TE 2009 NOV -9 Ah 11 - 20 - r iIR Afy ???1t, t..[ PENN CAA U A Qa . Nov, 3, 2009 11:25AM DAUPHIN COUNTY SHERIFF f?t?.i?re of 14C o'??prrff Mag Jane I E=% DSnyder Williaa. T. Tully GMt DMWD Coamy Harms Peonq 8Wx 17101 pk (717) 7806590 fox: (917) 255,2889 Jack op ick Commonwealth of Pennsylvania County of Dauphin No, 8025 P. 2 Charlm E.SShryeaffer Mic1 cWT art - x. o s'- yYc y Cis P T? AMERICAN GENERAL FINANCIAL SERVICES VS MICHAEL HOLMES Sheriff s Return No. 2009-CV-10543 And now: AUGUST 31, 2009 at 11:30:00 AM served the within WRIT OF EXECUTION & INTERROGATORIES upon PSECU-GARNISHEE by personally handing to AUDRA LABRANA; ASST. BRANCH MANAGER 1 true attested copy of the original. WRIT OF EXECUTION & INTERROGATOMES and making known to him/her the contents thereof at So Answers, L Sheriff of Dauphin County, Pa. Deputy: D ARTHUR Plaintiff: AMERICAN GENERAL FINANCIAL SERVICES Sheriffs Costs: $ PAID BY COUNTY ,OF THE P, -' ',`C AF , - .u 2009 NOV - 9 AN 11 0 PENNSYLVANIA 4t , $?.#-13 c D ? Z. (-e- 73-7 -1 3 1 .2 33/0