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HomeMy WebLinkAbout08-4490 Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MOUNTZ JEWELERS, L.P. : IN THE COURT OF COMM?N PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO.2008 - `f `f 9 D CIVIL TERM HARRY LAUGHLIN, H, Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered agaijnst you by the court without further notice for any money claimed in the Complaint or for any 'other claim or relief requested by the Plaintiffs. 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 Al 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 REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 F:\FILES\Cliems\6019 7022 Mountz Jewelers\6019.45.eom Created: 10/12/05 8:41AM Revised: 7/11/08 9:57AM Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MOUNTZ JEWELERS, L.P. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO-2008- 4496 CIVIL TERM HARRY LAUGHLIN, H, Defendant COMPLAINT AND NOW, comes Plaintiff Mountz Jewelers, L.P., by and through its attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby avers as follows: 1. Plaintiff, Mountz Jewelers, L.P., is a Pennsylvania limited patitnership with a place of business at 1160 Walnut Bottom Road, Carlisle, Cumberland County, Penn sylvania 17301. 2. Defendant, Harry Laughlin, II, is an adult individual residing at 4 Creekside Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff extended credit to Defendant for the purchase of jewelry. A copy of the Account Activity Report along with an invoice dated May 1, 2008, is attached hereto as Exhibit "A." 4. Plaintiff's periodic interest rate on all unpaid balances is 1.50% per month. 5. Plaintiff issued invoices and monthly statements to Defendants for all jewelry purchased on credit. 6. Defendant made payments on said accounts until June 21, 200. 7. Plaintiff has demanded payment of the balance in the amount of $5,513.47 and Defendant has failed to pay the amount due. 8. Plaintiff has fulfilled, performed and complied with all express and/or implied obligations and conditions agreed upon for the sale of the jewelry. 9. As of May 1, 2008, the principal and interest due and payJable by Defendant to Plaintiff was Five Thousand Six Hundred Eighty and 051100 Dollars ($5,680.05), with interest accruing thereafter at 1.5% per month. COUNTI BREACH OF CONTRACT 10. Plaintiff hereby incorporates by reference averments conta%ned in Paragraphs 1 through 9 of this complaint. 11. Defendant breached the expressed and/or implied obligations,; conditions and terms of the contract by failing to pay the amount due to Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant in l the amount of Five Thousand Six Hundred Eighty and 051100 Dollars ($5,680.05), plus interest at 1.5% per month, costs of suit, and any other relief as the Court deems just and reasonable. COUNT II IN QUANTUM MERUIT In the alternative, if this Honorable Court should determine that an express contract between Plaintiff and Defendant does not exist, which is denied, Plaintiff pleads the following: 12. Plaintiff hereby incorporates by reference the averments contained in Paragraphs 1 through 11 of this Complaint. 13. Having requested Plaintiff to provide jewelry, and doing $o to the benefit of Defendant, Defendant became liable to Plaintiff for said jewelry. 14. Defendant has been unjustly enriched by accepting said jewelry without paying Plaintiff reasonable compensation therefor. 15. The total amount by which Defendant has become enriched !is Five Thousand Six Hundred Eighty and 051100 Dollars ($5,680.05). WHEREFORE, Plaintiff demands judgment against Defendant in the amount of Five Thousand Six Hundred Eighty and 051100 Dollars ($5,680.05), plus interest at 1.5% per month, costs of suit, and any other relief as the Court deems just and reasonable. MARTSON LAW OFFICES By: Christopher E. Rice, Esquire Attorney I.D. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: Attorneys for Plaintiff In making this communication, we are advising you this firm is attempting to collect a debt for Mountz Jewelers, L.P. Any information gained from this communication will be used for that purpose. EXHIBIT "A" Mountz Jewelers Account Activity Report Included Store(s):'CA11IP 1-11 LL','CARLISLE'.'COLONIAL PARK','Cornorate','HERSHEY' Date Client Transaction Amount 12131/05 Laughlin II, Harry Starting Balance $0.00 nn,19,06 Laughlin IL Harry Cash-24686 $3,275.40 06/19/06 Laughlin 11, Harry Cash Payment ($3,000.00) Ow 1 106 Laughlin 11. Harry Visa Pavment ($275.40) 07,11 Or06 Laughlin 11, Harry Cash-26062 $52.95 07 111,'06 Laughlin IL Harry Cash Payment ($52.95) 08111506 Laughlin 11, Harry Cash-27711 $477.00 n8i0 106 Laughlin 11. Harry Cash-27718 $475.00 08105/06 Laughlin IL Hann Cash-27732 $630.70 08;05/06 Laughlin IL Harrv Check Pavment ($477.00) 08/05/06 Laughlin If. Harry Cash Payment ($475.00) 08,105/06 Laughlin 11. Harry Visa Payment ($630.70) 08/07/06 Laughlin IL Harry Cash-27750 $4,286.64 08,07/06 Laughlin 11, Barry Cash-27758 $276.92 08/07/06 Laughlin 11, Harrv Check Pavment (S4,296.64) 03,07/06 Laughlin 11, Harry Cash Payment ($276.92) 08/09/06 Laughlin 11, Harry Cash-27912 $800.57 08109;06 Laughlin 11, Harry Cash-27889 $302.10 08/09/06 Laughlin 11, Harry Visa Payment ($302.10) 08/09/06 Laughlin 11, Harrv Cash Payment ($800.57) 08/1 1/06 Laughlin 11, Harry Cash-27999 $524.70 08/1 1/06 Laughlin 11, Harry Visa Payment ($524.70) 08/14/06 Laughlin 11, Harry Cash-28144 $15.90 08/14/06 Laughlin 11, Harrv Visa Payment ($15.90) 08/15/06 Laughlin 11, Harry Cash-28251 $768.50 08/15/06 Laughlin 11, Harry Check135 Payment ($768.50) 08/16/06 Laughlin 11, Harry Cash-2$609 $1,060.00 08/16/06 Laughlin 11, Harry Check137 Payment ($1,060.00) 08/24/06 Laughlin 11, Harry AR-28880 S445.20 08/24/06 Laughlin 11, Ham AR-28881 ($768.50) 08/28/06 Laughlin IL Harry AR-29126 $312.70 08/28/06 Laughlin 11, Harry AR-29124 $450.50 08/28/06 Laughlin ?, Harry AR-29123 ($551.20) 08/28/06 Laughlin 11, Harry AR-29112 $133.56 08/28/06 Laughlin 11, Ham Visa Pavment ($22.26) 09/08/06 Laughlin 11, Harry AR-29923 $206.70 10/10/06 Laughlin 11, Harry AR-31968 $343.44 10/12/06 Laughlin 11, Harry Cash-32106 $0.00 10/18/06 Laughlin It, Harry AR-32506 $295.74 10/27/06 Laughlin 11, Harrv AR-33164 ($80.55) 10/27/06 Laughlin 11, Harry Check Payment ($206.70) 11/01/06 Laughlin 11, Harry AR-33472 $275.39 11/16/06 Laughlin 11, Harry AR-34581 $259.70 11/18/06 Laughlin 11, Harry AR-34797 $1,05735 11/18/06 Laughlin 11, Ham AR-34793 $755.25 11/20/06 Laughlin 11, Harry AR-34873 $1,017.08 11/25/06 Laughlin 11, Harry AR-35227 $3,295.12 11/29/06 Laughlin 11, Harry Finance Charges $8,38 12/21/06 Laughlin 11, Harry AR-38672 $3,174.70 12/23/06 Laughlin 11, Harry AR-39540 ($4,982.00) 12/30/06 Laughlin H, Harry Finance Charges $108,40 01/30/07 Laughlin 11, Harry Finance Charges $82.92 02/21/07 Laughlin II, Harry AR-44222 $755.25 03/05/07 Laughlin 11, Harry Cash-44935 $0.00 03/31/07 Laughlin 11, Ham Finance Charges $95.49 04/1 1/07 Laughlin 11, Harry AR-47186 $598.90 04/16/07 Laughlin 11, Harry AR47483 $16,026.14 04/30/07 Laughlin If, Harry Finance Charges $96.92 06/21/07 Laughlin 11, Harry • AR-52707 ($16,026.14) 06/21/07 Laughlin 11, Harry Check Payment ($2,500.00) 06/30/07 Laughlin 11, Harry Finance Charges $310.25 07/311/07 Laughlin 11, Harry Finance Charges $74.52 08/31/07 Laughlin 11, Harry Finance Charges $75.63 09130/07 Laughlin 11, Harry Finance Charges $76.77 10/31/07 Laughlin 11, Ham Finance Charges $77.92 12/31/07 Laughlin 11, Harry Finance Charges $79.09 01/31/08 Laughlin 11, Harry Finance Charges $80,27 02/29/08 Laughlin 11, Harry Finance Charges $81.48 03/17/08 Laughlin 11, Harry Ending Balance $5,513.41 MOUNTZ J E W E L E R S 3730 Trindle Road • Camp Hill, PA 17011 153 N. Hanover Street • Carlisle, PA 17013 't520 Jonestown Road • Harrisburg, PA 17109 Harry Laughlin, II 4 Creekside Ln Camp Hill, PA 17011-1304 04/30/2008 1.0 Finance Charges ACCOUNT SUMMARY (as of 05/01/2008) New Balance $5,680.05 Minimum payme t Due $0.00 Payment Due Date 05/12/2008 Statement Date 05/02/2008 '? - AlistBttdf:" $83.94 Account' Balance FIN'tute Rate' Bill 'Csyele Fitueutea Charges Purchases $5,596.11 1.50% 2 $83.94 i PrOW005 lWance Pmts & Credlits New Purchases Fiuenee Cbarltes Late S News Balance $5,596.11 $0.00 $0.00 $83.94 $0.00 $5,680.05 VERIFICATION acknowledge that I have the au?hority to execute this Verification on behalf of Mountz Jewelers, L.P., and certify that the foregoing Complaint is based upon information which has been gathered by counsel in the preparation'lof this lawsuit. The language of this Complaint is that of counsel and not my own. I have read the document and to the extent that this Complaint is based upon information which I have given to counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Complaint is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. tz ewelers, L.P. t?C- N v ? o% ?T tv w cn J l :w SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04490 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MOUNTZ JEWELEERS LP VS LAUGHLIN HARRY II R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT unable to locate Him in his bailiwick COMPLAINT & NOTICE , ut was He therefore returns the the within named DEFENDANT NOT FOUND , as to LAUGHLIN HARRY II 4 CREEKSIDE LANE CAMP HILL, PA 17011 PER SISTER, DEFEDANT MOVED OVER 5 YEARS AGO. HE BELIEVED TO BE LIVING IN MARYLAND. Sheriff's Costs: Docketing 18.00 Service 30.00 Not Found 5.00 Surcharge 10.00 Postage a JU910? ? 59 5 9 -63. So ' R. Thomas Kline She ff of Cumberland County SON LAW OFFICS /R 08/27/2008 Sworn and Subscribed to before me this day of A. D. FABLES\Clients\6019 7022 Mountz lewe1ers\6019.45.prarein Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MOUNTZ JEWELERS, L.P. Plaintiff V. HARRY LAUGHLIN, II, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 - 4490 CIVIL, TERM PRAECIPE Please reinstate the Complaint in the above-referenced matter. Date: MARTSON LAW OFFICES By: 4??? - - Christopher E. Rice, Esquire Attorney I.D. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff C7 '? - w 'p ? V t .~ 6 Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MOUNTZ JEWELERS, L.P. Plaintiff v. HARRY LAUGHLIN, II, Defendant TO: HARRY LAUGHLIN, II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2008 - 4490 CIVIL TERM NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the ~-7~ day of Qc ~~ e s , 2010, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $5,680.05, plus interest at 1.5% per month, costs of suit and any other relief as the Court deems just and reasonable as prayed for in the Complaint for failure to file an Answer to Plaintiff's Complaint. 7 .- ~ D / D a~a-,,cam- (~ C~~,~'~ /'l~`' Date: ~d '~ Prothonotary ~~,~ ~ Bu.el~ I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Harry Laughlin, II 125 West Tremont Avenue, Unit 230 Charlotte, NC 28203 ~ Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff F1E..~~3-~~ FiC C~ T~~: ~~„%~ t ~~fl"rti1T'~` ~'f ~ud~~G"1~~-~ Q~ ~~ ~~ MOUNTZ JEWELERS, L.P. : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. HARRY LAUGHLIN, II, Defendant TO THE PROTHONOTARY: NO.2008 - 4490 CIVIL TERM PRAECIPE Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant Harry Laughlin, II, $5,680.05, plus interest at 1.5% per month, costs of suit and any other relief as the Court deems just and reasonable for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant at the address indicated thereon, on November 4, 2008, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON LAW OFFICES By:~/I~` Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: / ~~ ~~~ ~~i,ooP~l ~y ~~3i ~ R~ x-563 yG N~3c c art Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MOUNTZ JEWELERS, L.P. : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : N0.2008 -4490 CIVIL TERM HARRY LAUGHLIN, II, Defendant 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 (10) 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 Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 Date: ~ f , y_ D ~j MARTSON LA OFFICES By: .~ ~~ Christopher E. Rice, Esquire I.D. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MOUNTZ JEWELERS, L.P. Plaintiff v. HARRY LAUGHLIN, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2008 - 4490 CIVIL TERM AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, Harry Laughlin, II, above named is not in the military service of the United States of America, that he has knowledge that the said Defendant is now living at: 125 West Tremont Avenue, Unit 230, Charlotte, NC 28203. Said Defendant's place of employment is unknown. ~~ Christopher E. Rice, Esquire Sworn to and sul this day of Public before me 2010. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M. Price, Notary Pubiicc Carlisle f3ora, CumbaAantl GouMy MY Corrrtr~5ion E~ires Aup.18, 2011 Member, Pennaylvenia AsapalNlpn pr ~~~ Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff MOUNTZ JEWELERS, L.P. Plaintiff v. HARRY LAUGHLIN, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2008 - 4490 CIVIL TERM COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant was given to him by mail on November 4, 2008. ~ ~ w Christopher E. Rice, Esquire Sworn to and subscribed before me this ~ day of , 2010. ublic COMMONWEALTH OF PENNSYLVANIA Notarlal Seal Mary M. Price, Notary Public Carlisle l3oro. G.unberland County My Comrnissior Expires Aug. 18, 2011 Member, Pennsylvania ~ssociatlon of Notaries ,, , CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Harry Laughlin, II 125 West Tremont Avenue, Unit 230 Charlotte, NC 28203 MARTSON LAW OFFICES By: ~ ` . Price en ast High Street Carlisle, PA 17013 (717) 243-3341 Dated: / ~oZ7//v This is a debt collecting firm attempting to collect a debt. Any information obtained will be used for that purpose. 1 Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff & FALLER~~~Ep-iJFFIC~ ~~ ~rEr ~R,t1 } 4~i~~~AR pp qq ^' ~-7 F° ~ 3~ 25 ~~.q; ,ri;.KT,L; ,;°~~ C~;~U~~i ~f,z~.;:~'~'L'~'~~1A MOUNTZ JEWELERS, L.P. Plaintiff v. HARRY LAUGHLIN, II, Defendant AFFIDAVIT OF SERVICE OF COMPLAINT COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND I hereby certify that a copy of the Complaint in the above captioned matter was mailed to Harry Laughlin, II, 19924 Sweetgum Circle, Apt. 42, Germantown, Maryland 20874, by certified mail, restricted delivery, return receipt requested. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2008 - 4490 CNII., TERM Attached is the Post Office return receipt signed and dated October 11, 2008. MARTSON LAW OFFICES By: 1 ~ n Christopher E. Rice, Esquire Attorney ID No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Sworn to and subscribed before me this o2~~G day of October, 2010. I N Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M. Price, Notary PubAc Carlisle eoro, Crmberland 1 X11 My Cornmissfon E ~9• Member, Pennsylvania Association of Notaries .-.~' ^ Camapilete Remy 1, 2, ar~3. Also complete lwn 4 if Restricted Delivery is desired. • P~Int your name and address on the reverse act that we can return the card to you. AMw~ft this sand to the back of the mailpiece, won 1~ie front if space permits. t. ANob+7ftfdressed to: f ~ 99a~ ~~ ~~ ~ ~b °Zo a ^ agent ^ adore by (Prinied7~am;e). ~ C. D. Is delivery rasa dilfererlt from Kam 7? Y ff YES, enter delivery address below: ^ No 3. Servbe 75rpe - ~Certifled Mail ^ E>q~ress Mail j7 Registered ^ Return Receipt for fNerGhandlM ^ Insured Mail D C:O,D. 4. Reetrictod DdNrery? (Extra Feel) ~~~~ !. llrwllf t>we~r ~--.--. AMarillr~ru a.;ittla.w.r - 7 D 0 8 1 Z 4 6 0 0 01 616 3 4 77 4 ' ~' F~arp 2004 aca>Mlc Rsarrn twoeapt t;o2ese~aa-M-re4o, l r` E m -a . ~ ... s .,.~.. '~0. $4` '~ . ... ..413''. rl P e ~ ; r ~~,., ~ Certllied Fee Y ~~:. ,: ~ ~~ G p ~ - Return Receipt Fee (F.ndoreementRequlred) ~~• I ~ ~~" ~ ~~~ ResMded Delivery Fee (Endorsement Required) 34,3n ^., ~' ~ a Total Postage & Fees ~ '~g.7~.". ~{1`/(lbj7[IIJr~ r~ M ~_.,, CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Affidavit of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Harry Laughlin, II 125 West Tremont Avenue, Unit 230 Charlotte, NC 28203 MARTSON LAW OFFICES By: O ~. M. Price Te ast High Street Carlisle, PA 17013 (717) 243-3341 Dated: /~~//(~ This is a debt collecting firm attempting to collect a debt. Any information obtained will be used for that purpose.