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HomeMy WebLinkAbout08-5902Our File No.: 183923 APOT'HAKER & ASSOCIATES, P.C. $Y: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PALISADES ACQUISITION XVI, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. KATHY REGELMAN 64 W MAIN ST APT 2 MECHANICSBURG, PA 17055-6276 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OB - 59CQ C iyi L -rerlm 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 Our file No.: 183923 APOTHAKER & ASSOCIATES, P.C. $Y: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PALISADES ACQUISITION XVI, LLC ) c/o Apothaker & Associates, P.C. ) 520 Fellowship Road C306 ) Mount Laurel, NJ 08054 ) Plaintiff, ) vs. ) KATHY REGELMAN ) 64 W MAIN ST APT 2 ) MECHANICSBURG, PA 17055-6276 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PALISADES ACQUISITION XVI, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are KATHY REGELMAN, an adult individual residing at 64 W MAIN ST APT 2 MECHANICSBURG, PA 17055-6276. 3. Plaintiff, PALISADES ACQUISITION XVI, LLC, is the Assignee and Successor in Interest of Account #5342010003319170; and said account was issued to Defendant(s) by NATIONS BANK, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $5,516.63. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. i ' WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $5,516.63 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. AYOTHAKE ASSOCIATES, P.C. Atte for Plaintiff A LZDavJ. in Debt Collection BY: aker, Esquire Dated: 9/24/2008 Our File No.: 183923 VERIFICATION David J. Apothaker Esquire hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 David unworn falsification to authorities. tha-Wer, Esquire for Plaintiff DATE: 9/24/2008 PALISADES ACQUISITION XVI, LLC KATHY REGELMAN 64 W MAIN ST APT 2 MECHANICSBURG, PA 17055-6276 STATEMENT OF ACCOUNT Debtor's Name: KATHY REGELMAN Account Number: 5342010003319170 Original Creditor: NATIONS BANK Balance Due: $5,516.63 Our File No.: 183923 EXHIBIT "A" ilk ca C -r 4 ? rz fir y CA w SHERIFF'S RETURN - REGULAR CASE NO: 2008-05902 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES ACQUISITION XVI LLC VS REGELMAN KATHY TIMOTHY R BLACK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon V r-WT,MATxT VATNV the DEFENDANT , at 0020:40 HOURS, on the 8th day of October , 2008 at 64 W MAIN ST APT 2 MECHANICSBURG, PA 17055-6276 by handing to KATHY REGELMAN DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.00 Affidavit .00 Surcharge 10.00 !e1/310y 9- .00 38.00 Sworn and Subscibed to before me this day of So Answers: RF 'Thomas Kl ind 10/09/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff A. D. r? Our file No.: 183923 " & APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 PALISADES ACQUISITION XVI, LLC ) Plaintiff, ) VS. KATHY REGELMAN ) Defendant. ) r O? 9? G?8 COURT OF COMMON PLl CUMBERLAND COUNTY DOCKET NO.: 08-5902 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on October 31, 2008, STIPULATED by and between Plaintiff, PALISADES ACQUISITION XVI, LLC, and Defendant, KATHY REGELMAN parties as follows: 1. Defendant agrees to pay the sum of $5,653.34, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $5,653.34 shall be paid by the by Defendant, KATHY REGELMAN, to the attorneys for Plaintiff in the following manner: a. $565.00 to be paid on or before October 31, 2008; b. $200.00 to be paid on or before the 30th day of each month, beginning November 30, 2008 until paid in full. All checks are to made payable to PALISADES ACQUISITION XVI, LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $5,653.34, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. r- ? f 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to KATHY REGELMAN by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for-,Plaintiff A Law Firm Eneaged,ffi Scian, TH REGEL r ?. _ .v;, ?;? 1 -;? ?.. c: ....? ?- . ,,? _.. i? _ 1 ...:.. :.',. i q..:.? ?.Z ' 4 } ?I ?. K.? w r AFFIDAVIT OF SERVICE PLAINTIFF GMAC MORTGAGE, LLC DEFENDANT(S) GEORGE G. DOLAN LINDA W. DOLAN SERVE GEORGE G. DOLAN AT: 25 COVENTRY DRIVE CARLISLE, PA 17015 CUMBERLAND COUNTY No. 08-5902-CIVIL TERM ACCT. #179463 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 4, 2009 SERVED Served and made known to I.T&gc c G• Defendant, on the 1 *74* _ day of X90-2001 at ; 0'6 , o'clock _f.m., at 3 '1O JA&g yUV EN 41 f- `` /nA-M P ?1 LL , Commonwealth of Pennsylvania, in the manner described below: 1/ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age W Height 5 Weight ?S Race W Sex M Other I, Ind XIA-c.D M0 LL , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at t h e address indicated above. * 5.4, 19 V#e, fib- , TANV E 41?•'t t r s 0 ? 4 r t 0 N p (SC C as" I-P*'f P pf f 1'T Sworn to and subscribed e4aa" Tvy Rf-St eJ" Q sao 4*vA*_A 4v ? ve--, O*m p ?4(.. before me this (-7 46 day of kicAm POA 200,2. Notary: BY 4?a PL?a PT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. ZJ. HARRIS NOTARY PUBLIC NOT SERVED STATE OF NEW JERSEY 8d&P!!M SSIOIWK c 4QWa0% _, 200_, at o'clock ^ m., Defendant NOT FOUND because: Moved Unknown No Answer 1St Attempt: Time: 3rd Attempt: / i Time: Sworn to and subscribed before me this day of _1200- Notary: ?(I- Vacant 2nd Attempt: Time: Attorney for Plaintiff DANIEL G. SCHMIEG, Esquire - I.D. No. 62205 One Penn Center at Suburban Station, Suite 1400 By: 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Z i ?? G t" r aa• W AFFIDAVIT OF SERVICE PLAINTIFF GMAC MORTGAGE, LLC DEFENDANT(S) GEORGE G. DOLAN LINDA W. DOLAN SERVE LINDA W. DOLAN AT: 25 COVENTRY DRIVE CARLISLE, PA 17015 CUMBERLAND COUNTY 1 No. 08-5902-CIVIL TERM ACCT. #175463 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 4, 2009 SERVED Served and made known to bl IVDA W, bbLA-N ,, Defendant, on the 174 day of bFC EM13 K 200 at S;DD ,o'clock -P.m.,at IS 110 RV+FRD /TvFNU?, 04MP 41 LL , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is GEok[E Da +v, 16SWD Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age 30 S Height Weight ((0 Race IA/ Sex M Other I, lko&Lt_o O "`01,t.. , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed 4 S'? 1 S v*"W T ' J ES t t I N to $GLp; E,b ? j De+" M*rr before me this .14 day C'u,u'r-`Y l '312,0 q?t o /?V.ru , La- A- of D 0" 2005[ No By: 7-,6? IACL?ta" LEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE THEODORE J. HARRIS ATTEMPTED. NOTARY PUBLIC NOT SERVED STATE OF NEW JERSEY 1V1&99VM1SS10N Ei>F PltS 1012WO12 200, at Moved Unknown No Answer Vt Attempt: I / Time: 3rd Attempt: / ! Time: Sworn to and subscribed before me this day of .200_. Notary: uZ (r o'clock _.m., Defendant NOT FOUND because: Vacant 2nd Attempt: Time: Attorney for Plaintiff DANIEL G. SCHMIEG, Esquire - I.D. No. 62205 One Penn Center at Suburban Station, Suite 1400 By: 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 z I?? '??''' Sri ?F ? c,?. y `" ; T "? -- W ?r., s¦ ? ?-" :? i.,i '^ ?/• gr ~ GMAC MORTGAGE, LLC Plaintiff, V. GEORGE G. DOLAN LINDA W. DOLAN Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-5902-CIVIL TERM AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 GMAC MORTGAGE. LLC, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,25 COVENTRY DRIVE. CARLISLE. PA 17015. 1. Name and address of Owner(s) or reputed Owner(s): Name GEORGE G. DOLAN LINDA W. DOLAN Last Known Address (if address cannot be reasonably ascertained, please indicate) 25 COVENTRY DRIVE CARLISLE, PA 17015 25 COVENTRY DRIVE CARLISLE, PA 17015 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name QUICKEN LOANS, INC. MERS as a nominee for Quicken Loans, Inc. MERS Last Known Address (if address cannot be reasonably ascertained, please indicate) 20555 VICTORY PARKWAY LIVONIA, MI 48152 P.O. Box 2026 FLINT, MI 48501 3300 SW 34TH AVENUE SUITE 101 OCALA, FL 34474 W 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program MERS AS A NOMINEE FOR CITIMORTGAGE, INC. CITIMORTGAGE, INC. 25 COVENTRY DRIVE CARLISLE, PA 17015 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 6th Floor, Strawberry Sq., Dept. 28061 Harrisburg, PA 17128 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 P.O. BOX 2026 FLINT, MI 48501-2026 1000 TECHNOLOGY DRIVE, MS 321 O'FALLON, MO 63368-2240 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsvfZ4n falsification to authgrities. February 2, 2009 DATE G. SCHMIEG, for Plaintiff A, GMAC MORTGAGE, LLC Plaintiff, V. GEORGE G. DOLAN LINDA W. DOLAN Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-5902-CIVIL TERM AMENDED AFFIDAVIT PURSUANT TO RULE 3129: GMAC MORTGAGE, LLC, Plaintiff in the above action, by its attorney, DANIL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was fil the following information concerning the real property located at .25 COVENTRY DRIVE. ISLE. PA 17015 ..._...? 1, -Name-and-address•of-Owner(s) or-reputed-Owner(s)- Name Last Known Address (if addit cannot be reasonably ascertained, pleandicate) GEORGE G. DOLAN LINDA W. DOLAN 25 COVENTRY DRIVF CARLISLE, PA 17015 25 COVENTRY DRII CARLISLE, PA 1701 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose juolt is a record lien on the real property to be sold: Name Last Known AIif address cannot be reasonably asc+ f please indicate) None 4. Name and address of last recorded holder of every mortgage rd. Name QUICKEN LOANS, INC. MFRS as a nominee for Quicken Loans, Inc. MERS ess (if address cannot be Last Knovained, please indicate) reasonabI 2055 ORY PARKWAY 205%I 48.152 LIV 026 F1fI 48501 34TH AVENUE :'01 k, FL 34474 5. Name and address of every other person who has any record lien on the property: Name None Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: reasonably ascertained, please indicate) Tenant/Occupant 25 COVENTRY DRIVE CARLISLE, PA 17015 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Internal Revenue Service Federated Investors Tower Department of Public Welfare TPL Casualty Unit Estate Recovery Program MERS AS A NOMINEE FOR CITIMORTGAGE, INC. CITIMORTGAGE, INC. 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 6t° Floor, Strawberry Sq., Dept. 28061 Harrisburg, PA 17128 13'h Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 P.O. BOX 2026 FLINT, MI 48501-2026 1000 TECHNOLOGY DRIVE, MS 321 O'FALLON, MO 63368-2240 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to uns falsification to auth es. February 2, 2009 C DATE D IEL G. SCHMIEG, PSI?Ul Attorney for Plaintiff a W 0 x 0 a: o a C 00 F) LT.. ? ?o y ? qb? b v2 zd? EO i6 3o03d¢ WOaq a371bry 8002 St03p 0Los tZb000 OZ T $ W4 ZO `?'H A3NJld '46 c .t r ry 0 0 3 F gg g g v O W PO a v, c 5, F a ?N w ?N u ? 3 U yy A a .... I..? i v >o d ° w d O n V?"d' U a . . ?•^ d ° a• 0,?d ?i v? a Q a_o °' 0''^ 0 vzSp In 004 a J ? .s h a N 00v t o tc 4. O A„ o?•a zU b 4 Li CIO O N ll H9 Ml, l i 1 K z Q rM 8ARl im t 9 ^'-•? . ? a3 i11 u? ,.711 YC1 .... aN a 1_ L m ? Z V W M W ? 0 ? Q r r ?? V A a ^' N M h ?D n 00 O -+ a Fry? oV a b ? as ? z co r ( r= IT. is ppp, V •? .7 u s £0 L6 L 3000 d?Z WOM:i U3-IIbW Sa E ° ?" m a 60OZ ZO 83=1 0 L08 LZb000 V4 z o c 5 z3 S?y1p9 A3NLd ® ? 1 , ? j b, C E W .$ ? O ? J O O ?5 8?ura E ? a €" E w C vYfE; ,C? o U o0 CE?wffi O 2 O p 0 ? g M dw "' q 0 W y '? .r p O O A 02 = E N ti u ? g d M ?O O? ? ? c s .d Rai N ? ? w fry w ? W ? "Od x M ? Noo z k ??a V ?HN? H?z A 00 ?° ?? ?o o O o o 3 ? O W H? w Pd x z' rMiW O Ua'? d Z w .r N M "r V I ?-p l? 00 O? .?- Nr en .?- ?. GMAC MORTGAGE, LLC VS. GEORGE G. DOLAN LINDA W. DOLAN : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION NO. 08-5092 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, DANIEL G. SCHMIEG, ESQUIRE attorney for GMAC MORTGAGE, LLC hereby verify that true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: February 2, 2009 '-4- a( IEL G. SCHMIEG, Attorney for Plaintiff T 70 (?7 Y7 co ? i t a v Our File No.: 183923 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff PALISADES ACQUISITION XVI, LLC Plaintiff VS. Defendant Civil Action PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION KATHY REGELMAN TO THE PROTHONOTARY: Please enter a judgment in favor of plaintiff, PALISADES ACQUISITION XVI, LLC, and against Defendant, KATHY REGELMAN, for failure to comply with the terms and conditions of the Stipulation in Lieu of Judgment (Stipulation), filed with this Court on November 25, 2008, a copy of which is attached hereto as Exhibit "A". Assess damages in the amount of: Balance: Less: Payments: Plus: Interest from November 25, 2008 TOTAL David P Attorney Dated: November 5, 2010 Pd. AA 1AA F E D O Fl! C 7 9 + f 3 r, l d, V 1 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5902 $ 5,653.34 ( 565.00) .00 $ 5,088.34 Esq. Our File No.: 183923 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff PALISADES ACQUISITION XVI, LLC VS. Plaintiff KATHY REGELMAN Defendant David J. Apothaker, Esquire, certifies as follows: Civil Action 1. I am an attorney with the Law Firm of Apothaker & Associates, P.C., attorneys for the Plaintiff in the above captioned matter, and as such, have full and complete knowledge of the facts herein. 2. The matter was settled by and between the parties by Stipulation in Lieu of Judgment (Stipulation), on November 25, 2008, a copy of the Stipulation is attached hereto and marked as Exhibit "A". 3. Defendant breached this agreement by failing to make payments in accordance with the terms of said Stipulation. 4. Therefore, pursuant to the Stipulation, Plaintiff is proceeding towards the entry of Judgment in the amount of $5,653.34, giving the Defendant credit for payments made totaling COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5902 $565.00, for a total of $5,088.34. I verify that the statements made in this that false statements herein are made subject to the unworn falsification to authorities. are true and correct. I understand of 18 Pa.C.S.A. §4904, relating to David J. ?jh o er, Esq. Attorney fo ,Plaintiff Dated: November 5, 2010 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KATHY REGELMAN 64 W MAIN ST APT 3 MECHANICSBURG, PA 17055-6276 PALISADES ACQUISITION XVI, LLC Plaintiff vs. KATHY REGELMAN Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5902 NOTICE Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. JUDGMENT FOR FAILURE TO COMPLY WITH THE TERMS AND CONDITIONS OF THE STIPULATION IN LIEU OF JUDGMENT ? JUDGMENT BY DEFAULT ? JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION ? JUDGMENT FOR POSSESSION ? JUDGMENT ON AWARD OF ARBITRATORS IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 215-634-8920 Our File No.: 183923 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff PALISADES ACQUISITION XVI, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. KATHY REGELMAN NO.: 08-5902 Civil Action Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 64 W MAIN ST APT 3 MECHANICSBURG, PA 17055-6276. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. i Mary M. Snavely-Dixon, Director of the fe se ?Jp erData Center has sent back our inquiry indicated that the Defendant(s) is/are n t in he ary. David J. Apot faker, Esq. 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R'AR2d Wr; 3bes ceelkaae was provided bowed an abame amd SSN prom ided by ac regae*a Provi&W an awagc om now Of SSF?T , wil camse aneraown ea?eme to be provi&& p ,,MltJ#P[)67Qj 183923 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY PALISADES ACQUISITION XVI, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) KATHY REGELMAN ) NO. 08-5902 To: KATHY REGELMAN 64 W MAIN ST APT 3 MECHANICSBURG, PA 17055-6276 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 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 ASSOCIATION 34 S. BEDFORD ST. CARLISLE, PA 17013 717-249-3166 Date: October 22, 2010 BAR DAVID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 Our file No.: 183923 r APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road 0306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 PALISADES ACQUISITION XVI, LLC ) Plaintiff, ) I t9 COURT OF COMMON PLI CUMBERLAND COUNTY DOCKET NO.: 08-5902 vs. ) r-a KATHY REGELMAN ) Civil Action = z " STIPULATION IN LIEU OF JUD?IEI-' Defendant. C10 r: The matters and things in controversy having been discussed by and hetweeathe parties, and a settlement having been agreed upon: It is on October 31, 2008, STIPULATED by and between Plaintiff, PALISADES ACQUISITION XVI, LLC, and Defendant, KATHY REGELMAN parties as follows: I . Defendant agrees to pay the sum of $5,653.34, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sung aforesaid of $5,653.34 shall be paid by the by Defendant, KATHY REGELMAN, to the attorneys for Plaintiff in the following manner: a. $565.00 to be paid on or before October 31, 2008; b. $200.00 to be paid on or before the 3e day of each month, beginning November 30, 2008 until paid in full. All checks are to made payable to PALISADES ACQUISITION XVI, LLC, and sent to: (r} ""'= Apothaker & Associates, P.C. F[j'UUDEC 520 Fellowship Road C306 Mount Laurel, NJ 080543. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $5,653.34, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to KATHY REGELMAN by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHA.K ,.R +& ASSOCIATES, P.C. Attorneys f laintiff A Law Furn Encom section Scian, Esqui XATTW RREGELM'AN Our File No.: 183923 PALISADES ACQUISITION XVI, LLC Plaintiff vs. KA-THY-REGELMAN ;-(o4 W-MainSr---- Apt 3 _ Defendant(s) Mech , PA 17o5S-(oo27le IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 08 -5902 - PRAECIPE FOR WRIT OF EXECOI' rn� To the Prothonotary: w .<v ca Issue a Writ of Execution in the above matter, �. Xa --- (1) directed to the Sheriff of CUMBERLAND County;cn (2) against KATHY REGELMAN, defendant(s); and (3) against M&T BANK 5219 SIMPSON FERRY RD MECHANICSBURG, PA 17050, Garnishee(s); (4) and index this writ in the judgment index (a) against KATHY REGELMAN, defendant(s), and (b) against M&T BANK 5219 SIMPSON FERRY RD MECHANICSBURG, PA 17050, as Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of Garnishee(s) as follows: Bank Attachment Only - All assets and accounts, including, but not limited to, bank accounts, brokerage firm accounts, stocks, cd's, insurance, safety deposit boxes, etc. (5) Amount Due $5088.34 Interest from November 19, 2010 $1023.80 Minus Payments made -$ Plus Costs $193.00 Total $6305.14 David J. Apothaker, Esquire Attorney for Plaintiff(s) + .00 I'b ATT/ Saw CBF 78.5o " Woo 4 fsq.50- Po Arti 4a.05 toeCo • 50 Li, c* IoaI u (O ;+ 41 w a Y oto‘..y THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net PALISADES ACQUISITION XVI, LLC Vs. KATHY REGELMAN WRIT OF EXECUTION (Pa R.C.P. 3252) NO 08-5902 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against KATHY REGELMAN, 64 WEST MAIN STREET, APT. 3, MECHANICSBURG, PA 17055 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of M&T BANKGARNISHEE(S), as garnishee, 5219 SIMPSON FERRY ROAD, MECHANICSBURG, PA 17050, ALL ASSETS AND ACCOUNTS, INCLUDING, BUT NOT LIMITED TO, BANK ACCOUNTS, BROKERAGE FIRM ACCOUNTS, STOCKS, CD'S, INSURANCE, SAFETY DEPOSIT BOXES, ETC. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $5,088.34 Plaintiff Paid Interest FROM NOVEMBER 19, 2010 - $1,023.80 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $159.50 Other Costs $193.00 Date: 5/30/14 (Seal} b A vi_o David D. Buell, Prothonotary REQUESTING PARTY: Name : DAVI.D J. APOTHAKER, ESQUIRE Address: APOTHAKER & ASSOCIATES, P.C. 520 FELLOWSHIP ROAD, C306, P.O. BOX 5496 MT. LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 1-800-672-0215 Supreme Court ID No. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLANDTCQUN}T . THE PRO i H NC T,, + 2G11iJUN -9 rti 3:O CUMBERLAND COUNTY PENNSYLVANIA OFncE QF THE SHERIFF Palisades Acquisition XVI, LLC vs. Kathy Regelman Case Number 2008-5902 SHERIFF'S RETURN OF SERVICE 06/06/2014 10:41 AM - Christopher Sharpe, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, M & T Bank, 960 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Angel Hetrick, Tele -Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 9, 2014 to Kathy Regelman at 64 W Main St, Apt. 3, Mechanicsburg, PA 17055-6276. RISTOP: R SH RPE, DEPUTY SO ANSWERS, June 09, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teeosofi. Inc. Our File No.: 183923 ) PALISADES ACQUISITION XVI, LLC ) ) COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY vs. ) KATHY REGELMAN ) NO.: 08-5902 64 W MAIN ST APT 3 ) –. ....... MECHANICSBURG, PA 17055-6276 ) Civil Action ri-f --- r`z•-i;- XXX-XX-6630 ) ) rs) r—;.--,,:_.- c_,_:, c- '- Defendant ) M&T BANK ) ..._ — Garnishee ) (41.5V#5 4114 INTERROGATORIES TO GARNISHEE TO: M&T BANK, Garnishee: 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(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed defendant(s) any money or were liable to defendant(s) for any reason? Lf.0 2. At the time you were served or at any subsequent time was there in your possession, custody, control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the defendant(s)? h.N.. 3. At the time you were served or any subsequent time did you hold legal title to any property of anynature owed solely or in part by the defendant(s) or in which the defendant held or claimed any interest? '\ n_ 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had any interest? 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration thereof? A \ 0- 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? N\pr 7. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant(s) have funds on deposit in an account in which funds are deposited electronically on a recurring tn.-- ii 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 and the entity electronically depositing those funds on a recurring basis. n 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant(s) have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed-the-arnount-of-the general-exemption under-42PA;C:S.§-8123? If so; identify-- - each account. ^no 9. How much is the value of any property in your possession belonging to the defendant(s)? $ 9 Ro- ll). In the space below, the plaintiff may set forth additional appropriate interrogatories. 44,_ /34/4fr .13/t7 '1009 _ Al 00,,, tsect,€:fiect t ufrioky nessi 7etzt orls ivoosteci Pro° c)r Le DatedDated //y ,v Pees David J. Apothaker, Esquire APOTHAKER&ASSOCIATES, P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel,New Jersey 08054 (856) 780-1000 t.AVg12 Attorneys for Plaintiff d/ijkjj' tANS°' isRS4- W' Our File No.: 183923 APOTHAKER SCIAN P.C. By: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 PO Box 5496 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PALISADES ACQUISITION XVI, LLC Plaintiff vs. KATHY REGELMAN Defendant M&T BANK Garnishee ``E PROTHONO JA;' 2014 Jilt. 21 1'l 1 26 L'Uf�18�RLAhlp PENNS yLVAN ANT' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5902 Civil Action PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, M BA K, dissolved. David J. Apothaker, Esquire Attorney for Plaintiff cowl- a9so,P0f co/ /1933