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Home My WebLink About08-6404r THE PATAPSCO BANK Plaintiff JOSEPH E. MARTIN GLORIA J. MARTIN Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: D&- (OYON 0,vit Term CIVIL ACTION - LAW N 0 T I C E 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, 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. Legal Services, Inc. 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 N 0 T I C I A Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Legal Services, Inc. 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 THE PATAPSCO BANK Plaintiff VS. JOSEPH E. MARTIN GLORIA J. MARTIN Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA : 4 G lfd Y ?'-?irP / eti- NO. CIVIL ACTION - LAW COMPLAINT 1. Plaintiff is The Patapsco Bank, a Maryland Corporation with an office at 2028 E. Joppa Road, Baltimore, Maryland, 21234. 2. Joseph E. Martin, a defendant, is an adult individual, with an address at 1945 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Gloria J. Martin, a defendant, is an adult individual, with an address at 1945 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 4. Defendants applied for loan from Plaintiff pursuant to the Application dated January 29, 2008 which is available but not attached because it contains social security numbers and other personal information. 5. Defendant's delinquent balance on the account is $7,482.50 6. Because of Defendant's failure to make monthly payments and in accordance with the Contract, a copy of which is attached hereto, marked Exhibit "A" and made part hereof, Defendant owes an attorney commission of $1122.38 for a total of $8604.88. 7. Defendants have failed and refused to bring this account current. 8. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. WHEREFORE, Plaintiff requests entry of judgment against Defendants in the amount of $8604.88 together with costs of suit thereon. Respectfully Submitted, Date: / b Z?( D0--- V t By: Arthur M. Feld, Esquire Attorney I.D. No. 07172 1309 Bridge Street New Cumberland, PA 17070 (717) 770-0292 09/03/2008 13:41 FAX -'one Improvement Installment G Tact ? 004/008 wyees Name(s Seller Namo ^ rasa es 9Lq Business Address 57-2 1 e- N IZA 0/ CS A/tZ, P.,F i70,S'O are words -r, -me-, 'Buyer and VOW rater to the Cusbmer and Co-Gus' Today I afros b purehaea from you, at to Total Sale Price, tha goods and/or omen apn(rap this odnmfdf. The words you' And "your* refer to fee Seller (or services described below for eosins, alterations or improvemerds to the real Holder M this contras is aseipnsd). Property located at: LDCatl0n: Street Address (and deocrmtion of real estate. it taker, 22 cnre,,ik,h Truth4n-Lending Disclosure Statement ANNUAL PERCENTAGE RATE FINANCE CHARGE AMOUNT FINANCED TOTALOF PAYMENTS TOTAL SALE PRICE The cost of rrry credit The dollar amount the The amount of credit provided The amount I will have paid The total coat of my purchase es a yearly rate. credit will cost me. to me or on my behalf after I have made All the on credit including my q 3 ' payments as echeOUlW, down payment of j ? a. °. eo S MY POYmhern iohedW6 will be Number OI,PaYme is Amount of Payme ma . . n PaMeas are u0 MRiffit SECURITY - I am giving you a security interest in the goods or property being Purchased, and 0 an address is filled in, a mortgage on real property located at., LATE CHARGE - if any part of a payment Is more than 10 days late, I will pay you 5% of the entire payment or S6. whie ~ is less. PREPAYMENT - If I pay of early, I may be entitled to a refund of part of the finance charge. FILING FEES - S CREDROR - The creditor making these disclosures is brae Seiler named above. See the contract documents for any addilforw information about nonpayment, default and any WA&W repayment in full balore the scheduled data. it you do not mgt your confto obii allons, you may bin the property mat you bought with this ban and, It an address Is provided in tta esaunty portion of the Truth h Lending Disclosure Statement above, you may also lose your house. Goo& and1w ices solo: Dosoeibe gently "attach eonlract w other compels desoipton, which Is incorporated into this oontrect by this refewes. For total Cash PrkO, see item 1 below. 114 3 - _ - LA Stella Okrrobsuru and Itemlraaon of Amount Financed °O 1. Cash Price (Total of all goods ardor services above) ...... S.7 2. Down Payment ................................................................... S A. Allowances Given by Con"obore ................................. S b. Cash Down Payment .................................................... S c. Total Down Payment (a + b) ......................................... ; w 3. Amount Paid on Your Account For )bur Pumhase (1 minus 2) ........................................................................ S e. Amount Paid to Othws On Your Behalf a, Official Fees o Public 01116als for Permit .................... S b. OMcial Fees to Public Officials for Recording Mortgage ...................................................................... S c. Official Fees to Public Officials for Rekasing Mortgage .................. _........................,........................ S V. Total Official Foils (a+b+c) ........................................ S 0. Total Amount Paid to Others On You Behalf (a + b + c) ....... ............................................................ S 5. Amount Flranced 3 + 4 ?. NOTICE-,ANY HOLDER OFTHIS CONSUMER CREDIT CON- TRACT IS SUBACTTO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST HE SELLER OF WITH GOOD SERVICES T HERETO OR HE PROCEEDS HEREOF RECOVERY HEREUNDER BY HE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY HE DEBTOR HEREUNDER, Property Insurance Is MgUk6d 01 give you a Mortgage, and may be puroheeed through any person of rhv choice. Terms and Conditions PMmNs- I apse to pay you #*TOW Sala price by maing the Cash Down Payment and Paying the inetalmada ai NhOrun in tie Th*WMAn hg Dleobsure Statwnwg Above. The Irtetalmems win been on a dais you eeled sftar the Imprownwts are competed. I will pay you or any person to which you MAIM tip Contract. AN Principal, intereat and a Menses not pnwim* paid In aaeoalsroe with ttie Contract we be Out oh the data Of the lest phgnnst AN pr4Klpal el.aknkhg unpaid at matutry we ronlimate bar=6WOr-LPriama 01ilf"Ontptwarsatalpwgftp? ftoWed lf permitted by law (or i( not, at the highest balyl fate). PMP W-ts -14u ran Prepay some or ell amounts die hinds No Contract at any tire. If you p awns, but rhct ail, amonns due rinddrthle Contract you wig not ? roe" any rei R uy SO amounts ON order ft Centred, you will ro- refund of the portion the FRW4CE d a we demantff f psym as of the dam PfePaYmant is received. 0 a delatlt occurs er . as ;retied below- PsY?t ct you debt, Will NANCE CHARGE as YOU to da MWWC a baked Of ire required. 1 w obj portA judgment ion of the reFl. quiridg Prepaym0nt at your debt, In irtlleon at law r M an a?ctiio of g?a mortga foroobsue, you ova a4o rodWte a rofushd of the hsheamad person d l ho l WCE CHARGE as of the data payment is required. All tef jn& wa Do O&IWA d accord, king b the Actuarial Mated. No refund of less than One Dole ($1.00) will be made. Default - If I am mere time 10 days late in paykp any part of an keplr Ant, I will PAY YOU ¦ Mire charge Bout to tix of to sewn kWAI ent or$6. whichever Is lass. If you accept lam PlVaRMS Or pared psymenta, that doss notmean you we accept other tam er partial payments. 01 do rot rake any of my scheduled paynwo within 10 days after they are due, or It I do not comply wah any ghat ro**Wrtenta of this contract Or of PAY mortgage securing" contract olfartybenkru; " orhedvency txocesdkhgs are comma oW by or against me, the hid amount I owe we become duo it you 001106, weout your AdvWng me, utiesl this oortaaot It sefaxad by A rod property mortgage. In that case, you mhos first delver any rodc6(s) u required by law and waft until the expirafon of the inks period speeded in such rwtioe(a). It you ratty thif OW*W to Outside counsel for collection stormy dsb* I agree to pay brat reasonable d ppayaage And QKPQr*ft Of your under such convaot too jhq qxW p1? n f by 1W and all oourt costs actually I ourrod ply you. It - FFb" any Interest WWI continue to accrue at the edosedd above it permitted by law (or lf not ow highest iwwl rote). (Co Wnuodan aAars/de) NOTICE: Provisions limiting Warranties and remedies ova(l- ebk to buyer and other Important provisions appear on the reverse side of this contract NOTICE TO HE BUYER: You may cancel this transaction at any time Without cost prior to midnight of the third business day titer the date of this transaction. See the attached No- tice of Cancellation form for an explanation of this right rbaos fug `J a- P A-2361 WHITE - BANK COPY NOTICE TO BUYER: (1) Do not sign this contract before you read It (2) You are entitled to a oomplete fillwNn oopy of this contract. (3) Under the law, you have the right to pay off In advance the full amount due end, under certain conditions, to obtain a partial refund of the finance charge- I acknowledge rewipt of a true copy of this Home Improve- ment Installment Contract which was completely fill" prior to my signing it - .-TI OY (Seal) 2 3 o (slat) uatomar m YELLOW - CUSTOMER COPY lMNK - CUSTOMER COPY EXliibI t-fl v0rvol4vv0 16.uz rxx gng/OOP (tbndnued bw iron) .. tiewrlty kearest - Wu wet ref ain a saourly hWW uhde the Uniform Commercial Cask In the goods or WDP KV sold Under 1115 contrast, Inaksfng praCeede and aceesalom, unts I have paid to Total of Psi mane In full and oct"IWy sdhfied d altar ragdlrsnwds of ate aorwaat and any mod aldlors tO IL I assign to you any Insurance proceeds relating to such goads IW are completely sabaled ea ohur ragdirarrsrdb of this CaaWAI and any rtnodaoatlona to R I assign to you arty Ineurarhee proceeds relating to persons or propwl% Including return of unearned pnmhsrw, for applicallon to the w"W balance. I died arty insurer to pay You dincdY- In his event of dekuh, you may cancel all Insurance and credl any refund to one WgNW balance- 1 had a choice of pairing sither the few cash sea price of a tna price (tree total ask price) and chose the epsr. Unless I notify you of a ehengs In my address, any fq I you said ma ers sufaoert ifsant to my addm" w 5hosro on ale Contract N I have given you a mortgage, I wE buy kwuMM In a bran and amourt satldsotory to you covering as aM $data agaiet Ask of I= or damage for the duraocn of this Contract. The insurance will Include a standard mortgage ehdopmwR and he proceeds Will be pay" w Itlerssla appeal Wu are not rsspondble to me for any lose or damage to me or my spate. servants or Mmploym duped by atone sham or by acts of God. cors4trcion delays, boor cokes or other causes beyond your control. It and when you request ahw all goods have ben Wmkhad and installed and work salsbalorly oompelad. I Will sign and dealer to you the Customers Certificate of Completion. If you assign this Contract to someone alp, I wldersend that you wll not act as roprNentatlw for caw odor party b receive pgwwm or for any odwr purposes. Any amounts you receive from me or an my ba W may be applied. at your option, that to any accrued curyas. This conflict oon sulm the Mika agreement of the parties harato with respect to its subject mater I w and to change in this CoMM will be binding an you a a Is not In asling and signed by you and ma. AN of your rights are cumulative. a anything In this Conbaa Is not valid or consistent with eve or regdstieons, it an be considered modified ortelekd so that It complies. Delaware law governs this WOW. Each parson who signs this Contract as Customer or Co-Customer Is Jointly and sawrWy lWte for W cbfigati ns of ormbnwfhem ndw.This Is a sealed Instrument. NO wAHRMTTIEB ExPRESsED OR IMPLIED, REP REswvviONs. PROMIans OR eTATE awe AS TOTHE CONwirm. FITNE>f6 OR MERCHANT ABILITY OF OR OTHERWISE AS TO THE GOODS AND afiRVICES SOLD AND FURNISHED HAVE SEEN MADE OYYOU UNLESS COVERED SY A SEPARATE WrATEMENT DELIVERED TO ME. A seternee se m year or model Is for WMgllicedw w4 No dwlg31 may be wads In ft nquiemenls Of I" pwagnph wdpe h wridng and s" by you end ms. a ey part a tftie par*Woo a mat pamited by eat tiet part will be trhdecdve, but ihs rernalnder a the paragraph wN remain In bee. h a wAMn warranty Is given by Seller, can atk *4 WW of Inplled warratAWWO not apW Pert of this C=Vaft The tams of cry document wwAed or provided In oonreolford with We ConbW arid labeed'CotrkaWftk ONW "NarranAl" or "Additional Provisions" sn hoorporsted in and made a part of this Cwdm4 AS For "JUS recaps. Sever ranby 311111, am" and trang11n WO to Aplgrna, tie seoopeors and aadQs, as WWM Orott1r110t, al m onto due and to became dw ttwwndw, and all Vt. we and tnrandaa.rwb wedtons PnapwlyanderV bfortgaga aewaktgfa Ow*aat,ephful powwntMAOelgrw nasortader a name, to else such legal or pilfer wow which War might have Wan save for this aselign" Satter, by ww llig Hater of hh/ efdw11Mrwds owdw d'WrDIOUT RECOURSE' or WITH FULL RECOURSE. ad" the provisions of and apneas whh Asslgw as 311 the In suds wndsserwds and war ow provisions of ft Contractors Agremet 31 In effect an the date of the Assign menL WITHOUT RECO/URRASE- Sellars Aselgnment shell, adapt for the provisional of the CorAMM h AgmenwA be wahout reoour31. War Name. _s.er//???RS ?L'/? ?/? (glPAt) py (riffAy WITH PULL AWOURSE - War isprep that, In addition to the PmvWm of Sur CordreClors Agr go of ds" by CuMomw in the Ala paymwd an eta der die Tweed of any ndalimant pqW* under fa C sibW or In rib prompt performance of Amy oblpmtion'a ba pMlamed under 90 Contract by CAMIONW. Seaw sill, dean demand be Assignee, bMwah repurchase Ins Cmhtrad from Assign es for a rephachal s price In cash egwl to as hnl unpaid balance of the TOW of Payments as of the date of such repurchase. SOWNerne; rBW or. r--- VERIFICATION do v states subject to the penalties of 18 Pa C.S.Section 4904 relating to unsworn falsification to authorities, that he/she is the 0o-e-0Qc.-tI cN? O *K E tAJL for the Plaintiff in this matter, that he/she is authorized to make this affidavit on its behalf and that the facts set forth in the foregoing pleading is true and correct to the best of his/her knowledge, information and belief. 1---f14 -f? LA ?. m V ;n c,rt -? SHERIFF'S RETURN - REGULAR # A&CASE NO: 2008-06404 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PATAPSCO BANK THE VS MARTIN JOSEPH E ET AL KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MARTIN JOSEPH E the DEFENDANT , at 0020:58 HOURS, on the 30th day of October , 2008 at 1945 SPRING ROAD CARLISLE, PA 17013 by handing to JOSEPH MARTIN 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: So Answers: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 R. Thomas Kline Postage 42 I? Js7?DY 33 . 42 10/31/2008 ARTHUR FELD Sworn and Subscibed to By: Z?K? before me this day D puty If of A.D. SHERIFF'S RETURN - REGULAR 6 OLCASE NO: 2008-06404 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PATAPSCO BANK THE VS MARTIN JOSEPH E ET AL KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MARTIN GLORIA J the DEFENDANT , at 0020:58 HOURS, on the 30th day of October , 2008 at 1945 SPRING ROAD CARLISLE, PA 17013 by handing to JOSEPH MARTIN HUSBAND OF 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 11'17/0F 4-, ? 16.00 Sworn and Subscibed to before me this day of , So Answers: .Thomas Kline 10/31/2008 ARTHUR FELD By: A. D. THE PATAPSCO BANK., Plaintiff vs JOSEPH E. MARTIN and, GLORIA J. MARTIN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6404 Civil Action - Law ANSWER AND NOW comes the Defendant by and through her undersigned counsel, and files this Answer and in support thereof responds as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. Defendant specifically denies and disputes owing the amount of $7482.50 to plaintiff and strict proof, explanation and evidence of the calculation of this sum is demanded. 6. Admitted in part and denied in part. It is admitted that defendant has failed to make all monthly payments. It is denied insofar as paragraph 6 suggest that no payments were made. Defendant neither admits or denies the amount of attorney fees. outright refusal to pay. 8. Admitted. 7. Denied. Defendant has never made and WHEREFORE, defendant demands judgment against plaintiffand that plaintiffs complaint be dismissed with prejudice. Date: I a - 3- 61 Leah M. Stump, Esquire ID. # 93211 J. Chad Moore, Esquire I.D. # 76660 Attorney for Defendant 270 Market Street Millersburg, PA 17061 717-692-5533 VERIFICATION LEAH M. STUMP, ESQUIRE, hereby states that she is the attorney for the Defendant in this action and verifies that the statements made in the foregoing pleading are true and correct to the best of her knowledge, information, and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Leah M Stump Attorney for Defendant THE PATAPSCO BANK., IN THE COURT OF COMMON Plaintiff PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6404 JOSEPH E. MARTIN and, GLORIA J. MARTIN Defendant Civil Action - Law CERTIFICATE OF SERVICE VS. I HEREBY CERTIFY that a true and correct copy of the foregoing Answer has been served by first class mail, postage pre-paid upon the following : Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 (717) 770-0292 o? - - yb? Date I.D. Xffibo U Leah M. Stump, Esquire I.D. #93211 Attorney for Defendant 270 Market Street Millersburg, PA 17061 (717) 692-5533 THE PATAPSCO BANK Plaintiff VS JOSEPH E. MARTIN GLORIA J. MARTIN ' Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA No.2008-6404 CIVIL ACTION - LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABL E, THE JUDGES OF SAID COURT: Arthur M. Feld, counsel for the respectfully represents that; plaintiff in the above action, 1. The above captioned action is at issue. 2. The claim of the plaintiff in the action is The counterclaim of the defendant in the action 18 $ 604. 0. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: J. Cha M- Stump, Esquire. WHEREFORE, d Moore and Leah Court to appoint three your petitioner submitted. (3) arbitrators to prays your Honorable the case shall be ARTHUR ELD ESQUIRE AND NOW, ORDER OF COURT petition, 2008, in consideration of the foregoing Esq., above captioned action Esq'' are appointed arbitrators inEthe, and (or actions) as prayed for. By the Court, . J. January 14, 2009 .o ? m m o q JAN ? n 2009 q THE PATAPSCO BANK Plaintiff VS JOSEPH E. MARTIN GLORIA J. MARTIN Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA No.2008-6404 CIVIL ACTION - LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Arthur M. Feld, counsel for the plaintiff in the above action, respectfully represents that: 1. The above captioned action is at issue. 2. The claim of the plaintiff in the action is $8604.88. The counterclaim of the defendant in the action is $ 0. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: J. Chad Moore and Leah M. Stump, Esquire. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to the case shall be submitted. ARTHUR M. FELD, ESQUIRE ORDER OF COURT AND NOW, a 2004, in consi ration of the foregoing petition, Esq. , A, Q _ ??,?,p,? Esq., and ti WLAIA-4-M-1 Esq., are appointed itrators in the above captioned action (or actions) as prayed for. By t a'W'C-o LIVI k, P.J. January 14, 2009 1. N C?j V N J czi M - 256 C3 THE PATAPSCO BANK., IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOSEPH E. MARTIN, ET AL., DEFENDANTS 08-6404 CIVIL TERM ORDER OF COURT AND NOW, this day of March, 2009, the appointment of a Board of Arbitrators in the above-captioned case, IS VACATED. Keith O. Brenneman, Esquire, Chairman, shall be paid the sum of $50.00. By Edgar B. Keith O. Brenneman, Esquire - li i rnbI/ 4C-? / Court Administrator _ eo P lacc& :sal to J. . R THE PATAPSCO BANK IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PA VS #2008-6404 JOSEPH E. MARTIN GLORIA J. MARTIN Defendant/s CIVIL ACTION - LAW STIPULATION FOR ENTRY OF JUDGMENT The parties hereto agree to enter a Judgment in favor of the Plaintiff and against the Defendant in the amount of $8604.88 plus costs. Date: Date: L/ 6 g Respectfully Submitted By: ? - Attorney for Plaintiff Arthur M. Feld, Esquire Attorney I.D. No. 07172 1309 Bridge Street New Cumberland, PA 17070 (717) 770-0292 By: torney for Defendants J. Chad Moore, Esq. 270 Market Street Millersburg, PA 17061 (717) 692-5533 FILED-RICE 'O;"OTARY OF die PP 2009 WR 14 PH 1 *- 17 k,t?•po Po ATM 4 Uq-UR THE PATAPSCO BANK Plaintiff VS JOSEPH E. MARTIN GLORIA J. MARTIN Defendant/s : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA No. 2008-6404 To JOSEPH E. MARTIN & GLORIA J. MARTIN You are hereby notified that on APRIL Wk , 2009, the following judgment has been entered against you in the above captioned case. JUDGMENT IN THE AMOUNT OF $8604.88 PLUS INTEREST FROM DATE OF JUDGMENT PLUS COSTS OF SUIT THEREON DATE: APRIL , 2009 li" a 4 roth ry I hereby certify that the name and address of the proper person/s to receive this notice under Pa. R. Civ. P. 236 is/are: J. CHAD MOORE, ESQUIRE ATTORNEY FOR DEFENDANTS 270 MARKET STREET MILLERSBURG, PA 17061 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION THE PATAPSCO BANK VS. JOSEPH E. MARTIN GLORIA J. MARTIN 1945 SPRING ROAD CARLISLE, PA 17013 Defendants ( ) Confessed Judgment (X) Other DISTRICT JUSTICE File No. dQ - Ll,(Q? Amount Due $8604.88 Interest FROM 04/14/09 Atty's Comm Costs. Total 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 CUMBERLAND County, for debt, interest and costs upon the following described property of the defendant(s) LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND 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) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against DATE : Signature: -J0-_1A v VZ-0 Arthur M. Feld, Esquire 1309 Bridge Street New Cumberland, PA 17070 Attorney for Plaintiff (717) 770-0292 ID No. #07172 FILED-OFFICE FILED-OFFICE OF THE PROTCHO NOTARY 1009 MAY 13 PH 1: 07 rrV VI I Fk?Nfi??>'?`L?r?? 33.42 ems. a!? . . ? 78 . sc> - ,. .r 7 8 . S'v - iy . ov ?c rt ?, Sv A2 -06 CK? ?r? sy? 1,c,,x p xEru?J- t o? ssc4-Qa . - .lb WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6404 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due THE PATAPSCO BANK, 'Plaintiff (s) From JOSEPH E. MARTIN AND GLORIA J. MARTIN, 1945 SPRING ROAD, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON DEFENDANT/S HOUSEHOLD GOODS AND PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $8604.88 Interest FROM 4/14/09 Atty's Comm % Atty Paid $192.42 Plaintiff Paid Date: MAY 13, 2009 L.L. $.50 Due Prothy $2.00 Other Costs . (Y"% ?71 L?u 4 s R. Long, P ono (Seal) By: Deputy REQUESTING PARTY: Name ARTHUR M. FELD, ESQUIRE Address: 1309 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717-770-0292 Supreme Court ID No. 07172 5/1-T WtLt* pqjx- "s -izr,-y uss4 . O.A-r A.:I? PATAPSCO BANK Plaintiff JOSEPH E. MARTIN GLORIA J. MARTIN Defendant/s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 08-6404 Civil Term CIVIL ACTION LAW PQ Would you please satisfy the judgment defendant/s in the above captioned matter. To Prothonotary April 19, 2012 against the Attorney for Plaintiff a K14 '% q Sa? `V" _1 ? I? r? 7flSS ?z? ?ut3y