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HomeMy WebLinkAbout08-7306NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court I.D. No. 43107 200 N. 3rd Street, 18th Floor Counsel For: GMAC P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA V. :NO. 730io Ci Vi 11? f V-.- JUSTIN A. HENNEGHAN, : CIVIL ACTION -LAW Defendant : ACTION IN REPLEVIN 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone: (800) 990-9108 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar kina apariencia escrita o en persona o por aboado 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 pars usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone: (800) 990-9108 NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court I.D. No. 43107 200 N. 3`d Street, 18`' Floor P. O. Box 840 Harrisburg PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: GMAC Dated: December 11, 2008 NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court I.D. No. 43107 200 N. 3rd Street, 18th Floor Counsel For: GMAC P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. JUSTIN A. HENNEGHAN, Defendant NO. 01f : CIVIL ACTION - LAW : ACTION IN REPLEVIN COMPLAINT AND NOW comes Plaintiff, GMAC, by its counsel, Nauman, Smith, Shissler & Hall, LLP, to file the within Complaint based upon the following facts: 1. Plaintiff, GMAC, an entity organized under the laws of Delaware, having offices throughout the United States and having an office at 555 Business Center Drive, Horsham, Pennsylvania 19044. 2. Defendant, Justin A. Henneghan (hereinafter "Defendant") is an adult individual presently residing in Cumberland County at 134 W. Penn Street, Carlisle, PA 17013. COUNTI REPLEVIN 3. On August 22, 2006, Defendant entered into a Contract with Sutliff Chevrolet, Harrisburg, PA 17105 (hereafter "Seller") for the purchase of a 2006 Chevrolet Malibu, bearing Vehicle Identification Number 1G1ZT5IF96F142019 (hereinafter "Vehicle") for a net purchase price and finance charges in the amount of Twenty-Three Thousand Nine Hundred Fourteen and 20/100 Dollars ($23,914.20). A copy of the Contract is marked as Exhibit "A", attached hereto and its contents are incorporated herein by reference. 4. Defendant, pursuant to the aforesaid Contract, agreed, inter alia, to make sixty (60) installment payments in an amount of Three Hundred Ninety-Eight and 57/100 Dollars ($398.57) each, commencing September 22, 2006, and payable on the same day of each successive month thereafter, for a total obligation of Twenty-Three Thousand Nine Hundred Fourteen and 20/100 Dollars ($23,914.20). 5. Under the Contract the Defendant granted the Seller or its assignee a security interest in the Vehicle and its proceeds. 6. Defendant, pursuant to the aforesaid Contract, agreed that in the event of default in any payment due under the Contract, or the failure to comply with any term or condition thereof, that the Seller of the aforesaid Vehicle may take possession of said property, including any equipment or accessories thereto, and for this purpose Seller may, in any lawful manner, enter upon the premises where the said property may be and remove same. 7. On or about August 22, 2006, for good and valuable consideration, the said Contract was assigned by Seller to GMAC who succeeded to the rights and interest of Seller. 8. GMAC, pursuant to the provisions of the Pennsylvania Motor Vehicle Code and the Pennsylvania Uniform Commercial Code, perfected its security interest in the Vehicle by properly notifying the Pennsylvania Bureau of Motor Vehicles to endorse upon the Certificate of Title for the 2 aforesaid Vehicle a notice of its encumbrance upon the aforementioned Vehicle and security interest therein. A copy of said Certificate of Title is marked Exhibit "B" and attached hereto. 9. Defendant has breached the said Contract in that Defendant failed to make the agreed- upon installment payments due. 10. Such defaults are continuing. 11. The present outstanding balance due GMAC from Defendant is in the amount of Thirteen Thousand Six Hundred Forty and 78/100 Dollars ($13,640.78), plus late charges and unpaid charges. 12. GMAC sent Defendant a Notice of Default by letter dated December 1, 2008. A true and correct copy of said Notice of Default is attached hereto as Exhibit "C" and incorporated herein by reference. 13. Under the terms of the aforesaid Contract, Defendant agreed that in the event he defaulted in any payment due thereunder, or failed to comply with any of the terms or conditions of the Contract, and in the event it became necessary for the Seller or its assignees to institute a suit in replevin for the Vehicle, Defendant agreed to pay all costs of suit and any reasonable attorney's fees. 14. GMAC has made repeated demands that Defendant make the payments agreed upon, all to no avail. 15. The aforesaid Vehicle is presently in the control and custody of Justin A. Henneghan, 134 W. Penn Street, Carlisle, PA 17013. 16. Vehicles of this model and class have an average wholesale value of Nine Thousand Three Hundred and 00/100 Dollars ($9,300.00). 3 WHEREFORE, GMAC prays that this Honorable Court enter judgment in favor of GMAC and against the Defendant for: a. Possession of the 2006 Chevrolet Malibu bearing Vehicle Identification Number 1G1ZT51179617142019 or in the alternative, the market value of the car in the amount of Nine Thousand Three Hundred and 00/100 Dollars ($9,300.00); and, b. Reasonable Attorney's fees and legal expenses incurred by reason of the institution of this action in replevin to repossess the aforementioned Vehicle; all as agreed to in the Contract dated August 22, 2006. COUNT II BREACH OF CONTRACT 17. Paragraphs 1 through 16 above are incorporated herein by reference. 18. Pursuant to the Contract, Defendant has defaulted by his failure and refusal to pay installments in arrears, the sum of which (including late fees and unpaid charges) is Two Thousand One Hundred Seventeen and 53/100 Dollars ($2,117.53) at this time and increasing monthly. 19. At all times material to this case, GMAC has fully and satisfactorily conformed to and complied with all terms and conditions required of it under the Contract. 20. Pursuant to the Contract, Defendant's default entitled GMAC to installments in arrears, a late fee equal to 2% of the total amount of arrears, plus all other costs incurred in connection therewith. 4 21. To date, Defendant owes GMAC the outstanding balance of Thirteen Thousand Six Hundred Forty and 78/100 Dollars ($13,640.78), plus unpaid charges, late fees and costs. 22. The Contract provides that in the event the Defendant did not make the agreed upon monthly payments, resulting in a default under the Contract, and GMAC was required to employ an attorney, the Defendant agreed to pay reasonable attorney fees and Court costs. WHEREFORE, GMAC demands judgment in its favor and against the Defendant for: a. The sum of Thirteen Thousand Six Hundred Forty and 78/100 Dollars ($13,640.78), plus a late fee equal to 2% of the total amount of arrears, unpaid charges in the amount of Four Hundred Ninety-Nine and 34/100 Dollars ($499.34) and all other costs incurred in connection therewith; and b. Reasonable Attorney's fees and legal expenses incurred in connection with installments in arrears; and c. Any and all other relief which this court deems appropriate. NAUMAN, SMITH, SHISSLER & HALL, LLP Weme Court I.D. No. 43107 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: GMAC Dated: December 11, 2008 5 VERIFICATION I, Sherrill Zarlengo, Semperian Agent for GMAC, being duly authorized to do so on behalf of GMAC, hereby make the following statements subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsifications to authority, and do state that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. A"G-4t.? S ll Zarlengo S perian Agent 4 GMAC Date: EXHIBIT "A" RETAIL INSTALMENT SALE CONTRACT GMAC FLEXIBLE FINANCE PLAN g2a 9/O//??+(` Dealer Number Co." Buyer lard Co•Bmyer)-Name and address (raduda counfy end coq code) Creditor (ssnsr name and addrw) waA USTIN A HENNEGHAN SUTLIFF CHEVROLET CO. g7i 34 V PENN ST P.O. BOX 1307 ARLISLE, PA 17013 HARRISBURG, PA 17105 00 UMBER AN You, au airier (and Co.Buyer, d any). ne youy 0e whets desubed below for cosh er on credit W m"v ass wrww, you dmn b buy to vshcs on pads hide ate tVae^tttt on ale front and bask of Ws contract you Was to pay us. Me Crelkbr. the Amaod Financed and France Chirps according to she payment sednafrM shown bakyw We corn hours ate Finance Charge on a daily b-s used! Year Minor arid MOM yahcte Identification No Penury Uses for Which Puidased 1='" ` ? personal, tenay. or fhousd old Oapreulhdal Vow trade naa Year sum FEDERAL TRUTH-IN-LENDING DISCLOSURES Msurance. You may buy the physical dvmq nwrace vas cawed regwas less bad) from ANNUAL FINANCE Amount Total of Payments Total Sala Price anyone you choose who u aecelptsble to us You are PERCENTAGE CNARGE Fkuinwtl The smart you The bW cat Of not required to buy arty odor assurance b older RATE The dollar The ensunt of will hen pad after your purchass W pearl Your decuan b buy or not buy odor The cal of your atreont do OWN provided to you have made all credit including insurance will not be a facbr in to peril approval crodn a aysery crede wit oat you or on your pia your downporyment process rate You behalf d#;?e?-u If any insurance is ducked below, policies or 9.90 % r III AS J&A)42 41& - Sic,, °2G entrants from the named insurance companies well describe the tams and arddoru Far Payment Schedule Will Be- below: t d sl I Number AnquM VAen Payments Ore an oe nsurance you wan CMak the of Payments of P A. Due FMowc Optional Credit Insurance. i Macey bepmxo J,2? p CreditUfo- ? Buyer ? Co•Buyer Term Lau Change. N a payment is not received in kill within 10 days alter it is due. you col pay a We ? Credit Disability (Buyer Oily) ,Norge. It to vehicle is a heavy comwrclal motor vehicle. the serge will be 4% of air part 01 no " T of the pal of the, payment has d phyrwnt ace a tete Oterwie, the charge will be 2%par parties. o tae, kpured bead w a fun akndar mate br any fart of a money the is more than 10 days Pre hem Prepayment. N you pay oft as your debt opal, you coal not two to pay a penally Credit Life S ?? Security IntwoL You are giving a sewny interest in the vehicle being purchased nformation including nfamaeon about f Credit Duai s -- or more i Additional Infurmatlon: Sae this contract nonpayment. dewA, any required repayment ,n lull before the sced,Aad dale, and security interest (insurance ) (tome Once Alldfts) ITEMIZATION OF AMOUNT FINANCED Crest Me vnsaence and crecat disability rmaarca t Cash pod (n0tut"'" any exeeaet cemv,cea and teas) Ib qqQ Q 1f) air ml ragarea b ahMn pe61 Your deaMOrt to , 2 TOW downpawnam Iv naaasve mser -W and ire Ire 4H below) buy or not buy 0068 Me insurance and cretlt disability insurance cod not be a lector in to pets grace tied" i u r a -eYaN b/"B" S Nib- approval prowess They call not be provided colas e re aerie-n i « pan $ @B ee- " you sign ant agres to pay to extra coal Credit Me . (2) S , . earn ( ndaanw pays tle unpaid pad of the amount OOc00- ; (31 3 thy?yp balance Celt pee l1 moos 2) financed d you do. This resistance pays only the ou would we if you pad as your payments amount 1 4 Oyer charges including amounts pad to others on yow bohall (Seiler may y on ire Credit deabldy insurance pays the keep pan of those annum). scheduled payments duo wider an m- - wide A Cost of optional credit ==me pad to the insurance you a0 clsabled This assurance does not carer crnparly or companies any namnito in Yom payment or in the number of The Payments o Byte i N/A d the m .e companies bmtl fo Disability $ N/A S WA coverage that credit life or credit -Mir, rwraoa 6 Oiler assurance paid to she insurance, company p -Wes Sao' :IM" Pokxw or carldcates for Usesonde) $ {A coverage knits and other him and cordtvhs C OMiOal fees pad b government apace S Olken Insurance. D Government axe not included in ash once ? E Govarnant Icerw ardfor regWnbon hie Type of bhsurarce Term S 5I A5 F Government centnale of etle fees Premium S MIA DO secenryinform recording S 27.50 G Other charges (Seller mat denefy who is pad and describe (Imureea Company) amn URAL 060/0060000 S 990.00 (Haw Office Address) LIWM L FEE s 60.00 I want Me mwanw decked above to to s N/A X to to, $ N/A Buyer Signature Date to fix $ N/A X to for $ N/A Co4Wyer Sgnabre Doke H Notyade-naWffb $ N/A Told other pegs and amens pad to others on your bash r3.312. 75 (4) a Amount erenced 13 .4) 113.8022 75 (s) ANY INSURANCE REFERRED TO IN THIS a Financechaa %LIL 45 L CONTRACT DOES NOT INCLUDE COVERAGE T TOW ot oawwma • yrw atenw f5 «ai 23.911-20 (67) FOR PERSONAL LIABILITY AND PROPERTY DAMAGE CAUSED TO OTHERS. 11 it You coo not move your cemr wwpwmv.w Vats ^'+r .'?? ry?..n...v. ^..^••`. HOW THIS CONT CAN B lGE ?cyyrhracl wrens the errors agreement between you ant w refining to this Mlr&Ct Any Change to the wntraol mu t a, p tl w ion m o td'charhgrs are binding r By- Co•Buyer signs X It shy part of 11 1 a not veld, at oinc, pads stay valid We may delay or ratan ban enforcing any of our right. ceder the contract "1110 A frump teem For example. ova may exert the unto for makng some payments without extending tea site for rwkop ciders You aupanze us to oblen information about you, or the vehicle you are buying. from to stake motor vehicle deparanet or other motor vehicle auuwnbes Bee bade lor other important eW-nt& Do not sign this contract on a Sunday. The Annual Percentage Rate may be nesgotlable with the Seller. The Seller may assign this contract and retain its right to receive a part of the Flnance Charge. Notice to Buyer. Do not sign s Conti in blank. You are entitled to an exactcopy of the contract you sign. Keep It to prot y ur 1 g ri is f9eryer srpa D1f22/2006 Co•Buyatugmx Date You agree ffl s of this contract. You confirm that before you signed this contract, we gave it to you, and re f ir-AI22/2006 and review it. You confirm that you received a completely N., Signs 'M filled-In py u Ig Co-Baya SysX Do" Co-BiArm erd CilioNeWmi - A &bya e a person who a resporeble for paying to Bare debt An other owner is s arson whose name is on cow tiw to ea. certrsct the canals but does not cove to pay air deb The other comer agrees to the soew,y nlereet in she vehicle b us in One owner ngns here X Dale caalp SUTLIFF CHEVROLET CO. 01422/2006 TALENT seder esr0a de rmrret n air cortraa b ? GeneralMotors Ac opunce (GMAC) G ? Nted Grew Corporation. under do terms of aril, epaanengq van asim,pws Assigned win recourse Assigned r km roaexsI SUTLIFF CHEVROLET AGENT Satyr Ties sewn Tree 2109 FR•PA 3rMM (1) (For use in oe Slob of Pennsylverea) (1 of 4) Notice: Sao Other Sift Copyright 2004 General Motors Acceptance Corporebon All Rights Reserved ORIGINAL OTHER IMPORTANT AGREEMENTS 1. FINANCE CHARGE AND PAYMENTS s. Haw we affil ftpure FWMM Charge. The Fauna Charge Is figured an a dart' bais at tlu Annual Pementago Wbe an the shield pad of the Amour Financed b. How we wag apply Payments. We Waft apply each Payment test to the erod and ulpr d pad at the Finance Burgs. and am to the upad pan of on Amount Financed. o. How lobe psyrmenta or early payments change whet you meet pay. We based to Fiance Charge. Tour of Payments. and Tour Sale Pan shorn on tlw from on the ass rnptim Bell you we make every parsent maw ay it ts due You Frwwe Gags, Taal of Payments. end Tour SW Price me be more it you pay Nate and haw d you pay salty. Changes may take an lain at a larger or peaks hael payment or, at our opion, more or Isar payments of the lama amoud ore your whodtled payment who a smaller final Payment We will sand you a now tang you abed than, changes before Ithis final scheduled pay"m is clue 2. YOUR OTHER PROMISES TO US a. If the vehicle Is damaged, destroyed, or losing. Y-gres I. pay us as you owe under this contract even if am vehicle is damaged, destroyed. or mssng b. Using the whkla. You agree not to remove the vehicle nom the U S a Ceara. or to sell. rem, tease. or "War any adarma in the vehicle or eve mnuecl without our wnSen p wm son You Was not to eapwa the volatile to misuse, 9arwia. ConieGlen. Of Involuntary transfer It we pay any raparr taA, enrage bias, taxes, hoes. or charges an the vehicle. you area to repay it* amount when in ask for it C. Security Interest. You give us a security liffeirest in 1. The vehicle and all pre or gdods installed in it, 2. NI money or goods received Waceea) fir the vehicle: 3 AN mn,rence. maintenance. service. or other oonhacu we finance for you and 4 AN pmocea . from suurarca, mee osence, service, or other eoraas we prance for you TM satuudes any refund. at premuns a changes, horn tw, mwaas This soeures payment of W you we on evs comaei It also Saturn you of er.spreemamis in this convect, Ym will make auto the Site an" der security interest (an) in am vows d. Imuranea you moat haw n the which. You agree n have physical damage deurana Covering tan or damage n ale "hate for Bar farm of he Contact The eeaallta real ewer our Merest in the vehicle. A you a not hive this nwruce. we may, if we deeds. cry physical damage MKMW e a we dews to buy phyereal image Insurance , we may buy nuaance that coven your intermit one our interest n to vehicle It we lay this insurance, we will bell you as arge you next pay To rtatrpa veal ba she pnmun bar Ule muuduca end a?lurar?¢ Chugs Sit M highest req to dew pent. It the vNwW is bet or damaged. you agree aW,wa'may;use any seruraree settlement to reduce what you own o. repair the vehicle e. Whet happens to returned insUf8me, ImMt a a, service, or O#wr contract Charges. It we get a Mond of auarce.'mibtene co, service, a other cmlrect charges, you agree that in may subtract the mhed from what you owe 3. YOU MAY PREPAY You may prepay es or pen Of M urlperd part of tlw Amount 9awnr:ed at any base without penally 't you a so, you must pay.to' serried and unpaid pert of an Finance Charge and all odor amounts due up to are del. at your payment. 4. IF YOU PAY LATE OR BREAK YOUR OTHER PROMISES a. You may cam late charges. You will pay a Into large on each late payment as sown on to from Acceptance of a Late payment or late aorta does not axarea your hale payment or mean dark you may keep mailing We payments If you pay late, we may also take the steps described babes b. You may have to pay all you owe at once. II you beak your promises (defaudI, we may anard that you pay aft you own on this contract atoms DoWO nouns, 1 Youanolpayrypaplweanbme, 2 You sta t a processing in bar"plcy or one a Bladed agaeW you or your property. or 3 You break any agreements in on coeacl The amount you who dew we be the unped part of the Mount Financed pia to reamed and unpaid part of an Finance Gage, my hat magus, and ay smbums due because you defaulted c. You may have to pay Collection costa. II you defwft and we have to go to mum to recover this "hide, you wa Pay the reaeaaW afe will's feet and caul eats. as to few Panama. You we MDO pay ay attorney's lees and Court mire a coud awema art d. We may total ate veld chi, from you. If you dslarat, we may take (repossess) an while from you t we do so pudefiwy and the haw etbws it If yaw vehicle has at electronic backing awn, you epee that we may use to device to find ante vehicle 11 ws here No vehicle. any Sometimes. equpmen4 and replacement parts will ally with the vehicle. It any personal Items are near vehkk, we may alas than fir you at your expanse. if you de not ask for than dems beck. we My depose of dam"that taw BOOM. e. How you Carl go the vehicle back If we take th It we repossess the vehicle. you nay get d Deck by paying the unpaid pad of the Amount Financed plus the lamed and unpW pan of the Fiance Charlie. any late ouron. and any other ammCUr" due benues you ddwkW (redeem) Your right to redeem nor when in re the vehicle. We wit tag you how touch to pay to redeem It we repossess; to vehicle, we may, at out opton, allow you to get the vet.cle back before we sea It by paying all par due payments Set ! Into creson (reretak) We w.1110 you it you may reinstate and how much to pay it you may 11 you were in delaull la more than 15 days when we moon the vehicle, ale amount you must pay to radeemh or me oars wall atso ahclude the expenses of fafdi g the white, holding A. and pmpwg ht for sale f., We will no the vehicle K you de nut get it back. It you de net redeem, we will all ate which We wall Sand you a written notice a( Sale before setting to vends W q will apply the many Iran the site, tau allowed expenses, bore amount you our Allowed expenses are expenses we pay as a direct result of Wdrg the vehicle. holding A preparing it fir sW, and an" it, as the taw lbws. Reasonable anomey leas and cad cats the law perils are him allowed expenses n any money is left (wxplut). we wet pay it to you. It money from the a" a not enough to pay she amount you owe, you must pry the rho to us. It you a not pay W. amount when we Sell wo may charge you interest at the highest lawful rate until you pay g. What in may a about opdonal Insurance, matntrnnee, servka, or other contracts. This aadrxl my Contain Charon for OPWO summuce, mramanrrm, sewn, a war mnaaaa t we repossess the "hide, we may cities beeahis under theca Corneae and canal them to Obtain mi ads of rnaamed charges to reduce what ym our or repair the vehicle b the vehicle s a total Iron, because it is Coralec919d, damaged, or Sailer, we may den bereft mar ante common, And camel trim b Clean refunds of untamed charges to reduce what you owe h. Summary, notln regarding prepayment and ralmtatement you may prepay all or part of gar snbu l you owe under Ws contact at any our without ponaey If you a so. you any have to pay to ended and unpad pin of this France Charge and ON other amanw due up b to date of your payment If you default add we repossess am vehicle. ma may. al our option, allow you to got as vehaie back before we sell it by paying ell paw due payments. IBM merges, and expenses S. W411"JITIES SELLER DISCLAIMS Tae baownp Paragraph does not affect any waawes covrldhy the v*vde tad ant vol da rrwMlaebrer may provide The toaawing parepaph also does 0 apply r ore it you bought the V*NCM W~Y for persaal, army, aththashofd use !Unless We Seiler makes a written warranty, or entere Into a service contract within 90 days from the date of this contract. the Sailor makes no wadndes, express a Import. an the vehicle, and Ihare will be no Implied warranties of mrob nMWIHy a of Names for a pard ulr purpose. fi. Used Car Buyers Guide. The information you wa on few window form fir this whkk is pan of this contract. Inforaueorh on the window form ovrndes any contrary provisions In the contract of sale Spanish Traeslatbn: Ggla pan comgWores a whleuka uaadaa. La infomtad6n clue w Sm at fomhWdo a In vwitanMa pia aura "Irlauk forma parts del presents caveats. La Inlonnacttn del Marmalade a is wntanVA dap sin efeoto led. dispeskidn an contrado comtamds an at consists a venw. T. APPLICABLE LAW ... Federal law and Parxgylvaraa law apply to an confect NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. COX 8X 014 EXHIBIT "B" s CERTIFICATE OF TITLE FOR A VEHICLE ,649 062363400011583-0031 16LZT51F96Fb42019 VbICLE IEMIFICATION NUNSER SDN l 13 BODYTYPE DUP SEAT CAP 8/24/06 # 8/24/06 DATE PA TITLED DATE OF ISSUE 2DO6 ! CHEVROLET - 1 63649690701 HE YEAR MAKE OF VEHICLE TIRE NUAlER 8/24/061 0003911 0 PRIORI Tr" STATE COW M40M DATE OODM MILES ODOM STATUS UNLADEN WEaff I QVWR I OCWR TTNt wwm ,n . •?et E.r AA}T,I?+e S RSMWMRED OWNERS) ) N J1 ?i ` I t ?ots+ri?!P•??aa+?n <4 sell JUST-IN A HENNEGHA 134 Y PENN ST 'r CARLISLE PA 17013 I POW LIEN FAVOR OF 6"A C FIRST LEN RELEASED ' DATE SY AURIORIg.D REPRESENTATIVE 1EAILS4 ADDRESS SECOND LIEN FAVOR OF ODOMETER sTATLAT 0. ACTUAL M JLAW . Mh,EAOE t XOCETS THE NECHAICAL %am 7. NOT TIE ACiWL WIL AGE 3. NOT THE ACTUAL WWAA0E4MO TER TAMPERMI VERIFIED 4. VWB r PROM ODMISTER DIECLOMIIE TITLE ERNRk A • ANTIxIE YEIILLE C . OLASW VEHICLE D . OOLLSC?EE.E VEISC?E F . OUT OP COUNrIW 0 . ORIGINALLY NFOD FOR NON U S DWTRIMION H . AdaOULTLS1AL VI I= L . L0004 V{9000I P . NAmms A POLICE VEHICLE R . I?.OTeTFA1CrH1 t - l7mm ROD T . rwDOYE® THM VEHICLE v . VENICIE COMM** R1,19IR T) VIN W . FLOOD VEHICLE X . OWA9 A TARO I • womld YINIONIr b Mood Tim wtWWOn Of Tn i,M YHA, to sIY .. . 1-u ff m IOn,w Ow Title to Ew awwY d Mom VshOw wIM to oiPmpms Imm Ina t" SECOND LIEN RELEASED DATE GY AUTNOPM REPRESENTATIVE GMAC PO BOX 8140 COCKEYSVILLE MD 21030 L ER • r M* w of ft am of "m m. mew TtOmdA of an PtrIItYI•LtRI ow" ALLEN D BIEHL. d TIfYI,MINIMIm mosm to tb pm"S? or = WN p IIIIOAI AbIIh ¦ No woo www ® d Ew tllt vtIMOY j saw*" at Tmompairim" I AND SWORW N a wAwcmw _cow vm you mom is bW wW you woo ow we b T • (On d@aM of am No a OMw, gm bNrwAv OINwr) CHECK MERE OLfrowlEs. NIE NEE wi be Spied Go 'Torj rat In Cmwnwf (OR due of am amm kaEGEI of doese d DTFRSr gala b h wAw heirs or soms) r.ONAnW OF PERSON TFRM OATH IST too ATE ? IF NO LEK CHECK cl IST UEt*DLDER STREET CITY STATE ap V V P V IF THIS IS AN ELT CHECK EIELE O FEIAIICIAL H01M FO REWIRED III?TITUTTON NO 2ND LIEN DATE ? IF NO LIEU CHECK 13 TI.. u,Awy?. hNwry •.F•• .V.IeMI,^ h• f.N.L..b a TIN q M wMN l.4.W W .W<I.NY dwr M b,b hw END LWNHOL.OER STREET asaN%I LIE or APFllr/ "oA AuTmo RED bamp CRY STATE DP F TIN *AN ELT CHECK HERE a ANANCNAL G,WjURI OF OPI/PUDAW rnU OF AUTMORI ZO SIGMA NOTE 1tAUM? EfaiRMgN NO 7 EXHIBIT "C" • Attorne4ys A~t Laws Please reply to P. 0. Box 840 Guy P. Beneventano, Esquire Harrisburg, PA 17108-0840 Guypbenny@nssh.com December 1, 2008 Via Certified Mail No. 7006 2150 0002 5370 7269 and Regular Mail Justin A. Henneghan 134 W. Penn Street Carlisle, PA 17013 In re: GMAC Account #020-9101-79125 2006 Chevrolet Malibu Dear Mr. Henneghan: Please be advised this office represents GMAC and in that connection, your overdue and delinquent account has been referred to this firm for advice and the appropriate action if not resolved promptly. This letter is an attempt by GMAC to collect a debt, and any information obtained from this letter will be used for that purpose. GMAC has advised you that under the terms of a Retail Installment Sale Contract, you are delinquent in paying the August, September, October and November 2008 payments in the amount of $398.57, respectively, plus late charges in the amount of $23.91 and unpaid charges in the amount of $499.34, for a total delinquency of $2,117.53. Unless you dispute the validity of the debt described above within seven (7) days of the date of this letter, we will assume that the debt is valid. If you notify us within seven (7) days that the debt is disputed, we will obtain further verification of the amounts owed and mail such verification to you. Pursuant to the terms and conditions of the Retail Installment Contract with GMAC that you signed, you are hereby called upon to cure the default by paying the sum of $2,117.53 within seven (7) days of the date of this notice. Please be advised that GMAC reserves the right to pursue all of its rights and remedies as indicated by the Retail Installment Sale Contract, which may include the seizure and repossession of the vehicle. You are also called upon to pay the attorneys' fees incurred by GMAC in connection with your default. Specific information concerning these attorneys' fees will be provided to you after GMAC's receipt of the total delinquency. Superior analysis. Effective solutions. Since 1871. Nauman Smith Shissler & Hall, LLP - 200 North 3rd Street - Harrisburg, PA 17101 9 717.236.3010 • fax: 717.234.1925 - www.nssh.com Justin Henneghan Page 2 If you fail to cure the default, GMAC will declare the entire amount you owe under the Contract IMMEDIATELY DUE AND PAYABLE. You may contact GMAC for the total amount due. If you wish to correspond to GMAC directly please contact: GMAC Attn: S. Zarlengo P. O. Box 380901 Bloomington, MN 55438-0901 You may also call S. Zarlengo at GMAC at 1-800-540-6821 Ext. 4510. If you do not dispute the, validity of the debt or otherwise promptly make the delinquent payments, then, GMAC will exercise its remedies, including (but not limited to) filing a lawsuit against you for the repossession of the 2006 Chevrolet Malibu and for breach of contract. If GMAC is forced to file a lawsuit against you, it will seek payment of the entire amount you owe under the Contract. I trust you will act to pay the delinquent payments, and thus avoid the expense and embarrassment of such litigation. Respectfully yours, Guy P. Beneventano GPB/sm cc: GMAC c oo T t-, y. \ 0 NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court I.D. No. 43107 200 N. 3rd Street, 18th Floor Counsel For: GMAC P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA : NO. og - 13o1v Civil Tem V. : CIVIL ACTION - LAW JUSTIN A. HENNEGHAN, Defendant ACTION IN REPLEVIN PRAECIPE FOR ENTRY OF APPEARANCE Please enter the appearance of Guy P. Beneventano, Esquire, as Attorney for GMAC, the Plaintiff in the above captioned case. NAUMAN, SMITH, SHISSLER & HALL, LLP uy . eneventano, Esquire reme Court I.D. No. 43107 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: GMAC Dated: December 11, 2008 CZ) C?a Q rrl C-11 7 ,: 4 C -rte ) SHERIFF'S RETURN - REGULAR CASE NO: 2008-07306 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC VS HENNEGHAN JUSTIN A KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN was served upon HENNEGHAN JUSTIN A the DEFENDANT , at 0017:00 HOURS, on the 16th day of December-, 2008 at 134 W PENN STREET CARLISLE, PA 17013 by handing to PATRICIA HENNEGHAN MOTHER OF DEFENDANT a true and attested copy of COMPLAINT - REPLEVIN together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.50 Affidavit .00 Surcharge 10.00 - 00 1 %", 32.5 0 Sworn and Subscibed to before me this of So Answers: . MTh as Kline 12/18/2008 NAUMAN SMITH SHISSLER HALL By. day , A. D. NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court I.D. No. 43107 200 N. 3rd Street, 18th Floor Counsel For: GMAC P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA V. JUSTIN A. HENNEGHAN, Defendant : NO. 08-7306 Civil Term : CIVIL ACTION -LAW : ACTION IN REPLEVIN PRAECIPE TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff, GMAC, and against Defendant, Justin A. Henneghan, for failure to plead to the Complaint in this action within the required time. The Complaint contains a Notice to Defend within twenty (20) days from the date of service thereof. Defendant was served with the Complaint on December 16, 2008, and an answer was due on or before January 5, 2009. Plaintiff provided Defendant with a written Notice of Intention to File Praecipe for Entry of Default Judgment which I certify was mailed on January 6, 2009, by regular mail to the last known address of Justin A. Henneghan, 134 W. Penn Street, Carlisle, PA 17013, which is at least ten (10) days prior to the filing of this Praecipe. Please enter judgment pursuant to Pa.R.C.P. 1037(b), 1071 and 1084 for possession of a 2006 Chevrolet Malibu, VIN 1G1ZT51F96F142019, and for $13,640.78, plus costs, for failure of the Defendant, Justin A. Henneghan, to file an Answer to Plaintiff's Complaint within twenty (20) days of service thereof. NAUMAN, SMITH, SHISSLER & HALL, LLP P. Beneventano, Esquire Supreme Court I.D. No. 43107 200 N. 3'd Street, 18`h Floor Dated:January 26, 2009 P. O. Box 840 Harrisburg PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: GMAC Q ?w O V T Cµ. ? ? ?--_, -? ?v ? -?, t? ? c- t c ?? sa" - " ? ^ i l ? ? +"" ?? . ` ? JAN-30-?009 FRI 11;04 AM FAX NO. 10 P. 02 NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court I.D. No. 43107 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 Counsel For: GMAC GMAC : IN TH Plaintiff : CUMBI V. : NO: 0 JUSTIN A. HENNEGHAN CIVIL Defendant TO: Justin A. Henneghan DATE OF NOTICE: January 6, 2009 YOU ARE IN DEFAULT BECAUSE YOU HA APPEARANCE PERSONALLY OR BY ATTORNEY COURT YOUR DEFENSES OR OBJECTIONS TO THE UNLESS YOU ACT WITHIN TEN (10) DAYS FRO JUDGMENT MAY BE ENTERED AGAINST YOU WI' LOSE YOUR PROPERTY OR OTHER IMPORTANT NOTICE TO A LAWYER AT ONCE. IF YOU DO N AFFORD ONE, GO TO OR TELEPHONE THE FOLLO' YOU CAN GET LEGAL HELP: Cumberland County Bar As 32 S. Bedford Stree Carlisle, PA 17013 Telephone: (800) 990-5 NA COURT OF COMMON PLEAS .LAND COUNTY, PA 7306 Civil Term .CTION AT LAW ['ICE E FAILED TO ENTER A WRITTEN ND FILE IN WRITING WITH THE LAIMS SET FORTH AGAINST YOU. THE DATE OF THIS NOTICE, A TOUT A HEARING AND YOU MAY GHTS. YOU SHOULD TAKE THIS C HAVE A LAWYER OR CANNOT ING OFFICE TO FIND OUT WHERE )elation 08 , SMITH, SHISSLER AND HALL Date:January 6, 2009 Y P eneventano, Esquire r7reme Court 1D# 43107 200 Nord Third Street P.O. Bork 840 Harrisbu? g, PA 17108-0840 Telepho? e: (717) 236-3010 Facsimfl : (717) 234-1925 Counsel for: GMAC NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court I.D. No. 43107 200 N. 3rd Street, 18th Floor Counsel For: GMAC P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. JUSTIN A. HENNEGHAN, Defendant : No. 08-7306 Civil Term : ACTION IN REPLEVIN NOTICE OF JUDGMENT TO: JUSTIN A. HENNEGHAN You are hereby notified that on N6I)n ( a9A , 2009, the following judgment has been entered against you in the above captioned case: Judgment in favor of Plaintiff, GMAC, and against Defendant, Justin A. Henneghan, as follows: Possession of the 2006 Chevrolet Malibu bearing Vehicle Identification Number 1G1ZT51179617142019, and for judgment in the amount of $13,640.78, plus interest, late fees, reasonable attorney fees, costs of collection, costs of repossession, costs of storage and all other charges as provided in the contract or as provided by law, and increasing monthly. Judgment was entered pursuant to Pa. R.C.P. 1047 for failure of Justin A. Henneghan to file a response to GMAC's Complaint twenty (20) days of service thereof. Yretflntj I hereby certify that the proper person to receive this notice under Pa. R.C.P. 236 is: Justin A. Henneghan 134 W. Penn Street Carlisle, PA 17103 NAUMAN, SMITH, SHISSLER & HALL, LLP P. Beneventano, Esquire Zl' Counsel for GMAC Dated: January 21, 2009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION GMAC, : ( ) Confessed Judgment (X) Other File No. 08-7306 Civil Term V. : Amount Due $13,640.78 Interest JUSTIN A. HENNEGHAN, : Atty's Comm Reasonable attorneys' fees qE) 31 W. QG & & Costs All Costs Cw (: s It j PA 1.7013 TO THE PROTHONOTARY OF 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. 2006 Chevrolet Malibu VIN 1G1ZT5lF96F142019 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 for the following property (if real estate, supply six copies of the description; supply four copie(S of lengthy personalty list) 2006 Chevrolet Malibu VIN 1G1ZT51F96F142019 0 (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 3 ' 2 3 ' g Signatur . Print uy P. Beneventano, Esquire Addres : P.O. Box 840 Harrisburg, PA 17101 Attorney for: Plaintiff Telephone: (717) 236-3010 Supreme Court ID No.: 43107 JP& a -c 4r qtl?s o °cl V.1 °_Q ?xS ci r:a TIZZ? L -csaL` s f WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N008-7306 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC Plaintiff (s) From JUSTIN A. HENNEGHAN, 134 W. PENN STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell 2006 CHEVROLET MALIBU, VIN 1G1ZT51F96F142019. (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$13,640.78 L.L.$.50 Interest Atty's Comm %REASONABLE ATTORNEYS' FEES Due Prothy $2.00 Atty Paid $165.50 Other Costs Plaintiff Paid Date: March 25, 2009 Cutfis R. Low on (Seal) By: Deputy REQUESTING PARTY: Name GUY P. BENEVANTANO, ESQUIRE Address: P.O. BOX 840, HARRISBURG, PA 17101 Attorney for: PLAINTIFF Telephone: 717-236-3010 Supreme Court ID No. 43107 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GMAC, CIVIL DIVISION V. JUSTIN A. HENNEGHAN, File No. 08-7306 Civil Term Costs Plaintiff Paid Deft, Paid : Due Proth/Clerk PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY OF SAID COURT: (X) Issue Writ of Possession in the above captioned case and direct Sheriff to deliver possession of the following property to Plaintiff. 2006 Chevrolet Malibu, VIN 1G1ZT511796F142019 to satisfy the costs against the defendant, direct Sheriff to levy upon the interest of the defendant in the following property and to sell the same: (X) Personal property as follows: 2006 Chevrolet Malibu, VIN 1 G 1 ZT51 F96F 142019 L) Real Estate as per the attached description Date Signat e: Pri uy . Beneventano, Esquire Ad P.O. Box 840 Harrisburg, PA 17101 Attorney for: Plaintiff Telephone: (717) 236-3010 Supreme Court ID No.: 43107 WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND: TO THE SAID SHERIFF OF CUMBERLAND COUNTY (1) To satisfy the judgment for possession in the above captioned case, you are directed to deliver to the plaintiff(s) possession of the above described property. (2) To satisfy the costs against the defendant, you are directed to levy upon any property of the defendant and sell the defendant's interest therein. Date_ V7 rothonot erk, C' it Division COMS: 187.00 P0 Arn A.00 huea By: Deputy r.1 ?J OF ?t 209.1 *aq • °° p 13 51 50 CogF 88.50 14.00 t4.O F, 34.00 $a•00 ISUec° ??-,? 3stt`1 ? aa33st? ()ti ?- R Sheriffs Office of Cumberland County R Thomas Kline rV of cumb,, Edward L Schorpp Sheriff' Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE wF =>'eRIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/20/2009 02:55 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on April 20, 2009 at 1455 hours, he served a true copy of the within writ of possession, in the above entitled action, upon the within named defendant, to wit: Justin A Henneghan by making known unto Pat Henneghan, mother of defendant, at 134 W. Penn Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. 04/21/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned SATISFIED. SHERIFF COST: $76.42 K- ;g1..11,09 'J.- April 21, 2009 ,, p, y 3 nC. SO ANSWERS, /r R THOMAS KLINE, SHER FF B aron R. Lan z By virtue of this writ, on the 20th day of Aril , 2009 , I caused the within named GMAC , to have possession of 2006 Chevrolet Malibu, VIN 1G1ZT51F96F142019 Sworn and subscribed to before me this Day of So Answers, Sheriff 1401 By L2 Sharon R. Lantz .?, v-a Ce . t? L y>G e u ?2 vv -1 t( FILED -C)i--.z, OF THE 20G4 APR 21 Pil=l 3: 09 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GMAC, : File No. 08-7306 Civil Term V. : Costs : Plaintiff Paid JUSTIN A. HENNEGHAN, : Deft. Paid : Due Proth/Clerk PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY OF SAID COURT: (X) Issue Writ of Possession in the above captioned case and direct Sheriff to deliver possession of the following property to Plaintiff. 2006 Chevrolet Malibu: VIN 1GIZT5IF96FI42019 to satisfy the costs against the defendant, direct Sheriff to levy upon the interest of the defendant in the following property and to sell the same: (X) Personal property as follows: 2006 Chevrolet Malibu, VIN 1_GIZT51F96F142019 U Real Estate as per the attached description Date 9 S ignat Prim uy P. Beneventano. Esquire P.O. Box 840 Ad 911,-6 Harrisbura, PA 17101 Attorney for: Plaintiff Telephone: (717) 236-3010 Supreme Court ID No.: 43107 WRIT OF POSSESSION COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: TO THE SAID SHERIFF OF CUMBERLAND COUNTY (1) To satisfy the judgment for possession in the above captioned case, you are directed to deliver to the plaintiff(s) possession of the above described property. (2) To satisfy the costs against the defendant, you are directed to levy upon any property of the defendant and sell the defendant's interest thA ' Date W 7 Pr t r , tvil Division : 187.oo Po ATTY 2.00 1>Uea By: Deputy ., '7? ?r I l; iJ'i? I' ?f {:.?.? _. ?I.?