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HomeMy WebLinkAbout09-1708COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff No. o Q l? lvL? VS. PREETHIKA FAROOK CIVIL ACTION Defendant NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 AMATO IATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 ,. Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff vs. PREETHIKA FAROOK Defendant(s) CIVIL ACTION COMPLAINT The above Plaintiff brings this action against the above Defendant to recover the sum of $25,044.43, with interest thereon as hereinafter stated, upon the following cause of action: 1. Plaintiff, SOVEREIGN BANK, is located at 1 Sovereign Way, Providence RI 02915. 2. Defendant, PREETHIKA FAROOK, is an adult individual located at 102 November Drive, Apt. 1, Camp Hill, PA 17011. 3. At the request of Defendant, Brenner Motors, Inc. entered into a written contract with Defendant for the purchase of a motor vehicle ("Contract"), a true and correct copy of which is attached hereto, made a part hereof and marked Exhibit "A". 4. For value received, Brenner Motors, Inc. assigned, transferred and set over all of its rights, title and interest in the Contract to Plaintiff. 5. By virtue of said assignment, Plaintiff acquired legal title to Defendant's account and became the holder of all claims against Defendant arising under the Contract. 6. Defendant has not adhered to the agreed repayment obligations set forth in the Contract, by reason of which Defendant is in default thereof. 7. The total amount which became due as a result thereof, after allowance for all proper credits for payments and/or adjustments, if any, was $18,616.83. 8. Plaintiff is entitled to receive interest on the above amount determined by applying the agreed interest rate of 13.34% per annum to the past due balance. 9. As of March 13, 2009 the total amount of interest due to Plaintiff is $1,959.57. 10. Plaintiff is entitled to have the 13.34% interest charge continue to accrue as set forth above, from March 13, 2009 on down to the date of judgment in this matter. 11. In accordance with the Contract, Defendant further agreed to pay Plaintiffs reasonable attorneys' fees incurred in the collection of any balance due Plaintiff, which total $4,468.03. 12. Plaintiff has made demand against Defendant for the aforesaid sum, but Defendant has failed or refused to pay the same or any part thereof. WHEREFORE, Plaintiffdemands judgment against Defendant for $25,044.43 together with the continually accruing interest charge at the agreed rate of 13.34% per annum from March 13, 2009, costs of suit and all other relief to which Plaintiff may be entitled. COUNTII Alternative to Count I - Unjust Enrichment 13. Plaintiff incorporates the allegations of every paragraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. 14. At Defendant's request, Plaintiff conferred a benefit upon Defendant by providing the auto loan services described in the exhibits attached hereto. 15. Defendant received and accepted the benefit of said auto loan services provided by Plaintiff. 16. At all times material hereto, Defendant was aware that Plaintiff was providing the aforesaid auto loan services to Defendant and that Plaintiff expected to be paid for such. 17. At all times material hereto, Defendant, with the aforesaid knowledge, permitted Plaintiff to provide said auto loan services and to incur damages. 18. At all times material hereto, Defendant was unjustly enriched by retaining the benefit of receiving said auto loan services without paying Plaintiff fair and reasonable compensation. 19. Allowing Defendant to retain the benefit of said auto loan services without paying fair compensation would be unjust. 20. By reason of the aforesaid unjust enrichment of Defendant at Plaintiffs expense, an implied contract exists between Plaintiff and Defendant and Defendant is obligated to pay Plaintiff the quantum meruit value of the auto loan services described in the exhibits attached hereto in the amount of $18,616.83. WHEREFORE, Plaintiffdemands j udgment against Defendant for $18,616.83 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from March 13, 2009, costs of suit and all other relief to which Plaintiff may be entitled. AB SSOCIATES, P.C. y: MTO Ronald Amato, Esq., Atty ID #32323 Z= 3::-,_ ?- ? Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM 01/21/2009 09:17 6098239598 PAGE 02/02 Jan, 20. 2009 3:56PM AMATO AND ASSOCIATES PC No, 1612 P. 2 Y6RMATIQIV ?-5 a_??t=oFF C o?, hereby states that he/she Is the l nnske L? S P2c10l.s4 of 5S,0 L?n Plaintiff in this action, and verifies that the statements made in the attached document are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S.A. 6 4904 relating to unworn falsification to authorities. ca z JAN 2 C 2009 11/25/2008 13:49 6098239598 H: ... .. .... , . . * YMIANIA Al TQ?A VEPICLE INSTALLMENT SALE CONTRACT, In this Cc ntract Doted IIAY 241td We are 1612-30 PAXTON• ST the SELLER. gR OVKR MUM IRS, ING HARRIS)S me PA 171 Name Address PAGE 06/09 Lip ode MONEY ON nprwrr Wf TH • H °;; You are the BLRER(S). FIIN• TEASSKVfEE SNEYARD F FMM * 3$24 jonVgBER DRI CoVEun"•ty 1 DA[9PHILT1 PA i 7811 T* C111*.a t is 111119000 War and &4W. AN PREETkfIKA FRS 3g2q deeimrsoe have been merle by Setter. Seger PRE ? R DRIVE #x CAl'Q HILL PA 17011 '"t1fift11$1Fft WMtotheAxs1grwo. up uode" County QL McERLAND If there Is more than one Buyer, each promises, separately and 1098thef, to pay all surta due us and to perform all iihmements in this Contract TRADk•IN: you have traded in 2M 'PWIAC OJIU f3 PRIX • 4 DOOR. SEDAN the folf*w ngvehicle: Year and•hlalre Description No balm a id atlg owillg on the vohk* you have traded 1141118 Was wig pay tiff this amount on Ally trade. n is five irons claim, enouniblasce orceclrri . your trehalE You warrant and iepresarlt to us that !Y 1AIRmt, OW as shown in the ItwrtixaBorr of Amount Fietenrmd" as the 'Lien PayofL' PROPEI f INSMN(X. You may drew thl Person througtr whom htsuAl" fI•ahhhled ow bo or darojw to the Vehicle and ag tester o of rae crowneramp a the Whicia, to dds Clo*sd YOU eta promiaf to itmtris ttb Yehkh and Iaeep it Ygered. _ DEBT CAiCW{O ED AUM PROIEI;TtON) AGREEMENT IS VOLUNTAxy mD NOT REQWRED A& A CONDITION OF THE CEO" hb alt eM WE not be Mortded unless YOU af9rt below, agree to pay the additionadderg8, end 81111"-the w 11111011111 paA +sbfoh is part of this Conhot This agraernent will appbIdurtngthe eagre teem of the Omira L This a ren diay no ra and yauRentirl indMttedfarNrmthe MAXIM PfLOfECiION amontsWWWW'n thomparate d6cloaure and aw,aamani. may not cover Of Debt 011"looffaft Quaraetead auto protection (GAP) 84iSI "i 520.08 - _ paid to &Wistax Of Cash prim t 28763.04 Cash Dmmpayment 55041.88 Value of Trade-in Uen p"WIu,ORiVE1F unpaid Cash Price Balance 62440.45 p don Opilo"A Debt camel"" (GAP UIVICE 12XINTRACT ORA#1gtRI M A& MENT IS VOLUNTARY AND NOT REQUIRED AS CON aviftk Of lrarislNty 1111111111100 wilt nit be pwvtded union: you sign the separate a E. C#F?11T. The service named abine, and agree to pay the addttio W cha This greemebt wM tII ird forty provider, who Is not the Seger urn cgs season does not apply to any warranty that you may receive for which there is no "Pro _ C!tlDtT INStIIEI m Iti.NOT REQWFp; CroditLife lneumnce and Credit Audderrt & Health pubiBt l Ire:uranco-m not and w*1W* •be P"bled union you slpl below and agree to pay the addWonal MeW m obtaIn IE an fhe reverse aide for a descriptim at coverage. Your4nSuronce 0pp0olky f'le- read the NOTICE OF PROS VW- NS AN nrsurarn x pnrobasad•wN be for the term o e cm k we may m0efve Bancfaf benef'h from yowill ur porchasg of of ora p unch e+r adItRfn In about your-insurance: o crarrarrce. By .ice saleOt smog ca fe Insurance, What La your By sfgning, you select Single Credit Accident & whfcli costa 0987 • Yoors I Health Insurance. Which costs; era' Buyer 16 b* inland for Slagle Credit Li a tourance U7 iyoutamsaiadjoint NIA Whatare CArdlt Lire lnsur0ncre, which cott:9 yoursgw 1. What hr your N/A Years t5geahae Of 131-W to be lolured far nglaum ' nt "b Insurance- f8Y%ftHivbothunairoo vtCMdtoosts= Percentage your*d to he Insured I t' EXHIBIT - x 2 ? Tags and RoOstrayp„ 64.50 Lien Fee S 5.80 I'axas Not Included in Cash price $ 5.88 For Messanaar senile' N/A E Greg Insurance company 11/25/2008 13:49 6098239598 ASSf*Ri6S: Wo may 43d PACE 07109 arl Oontno the rar? arw SecurlIY Agreement the Coetmd to a subsequent Agreement to a sales finance company which is the MAsst ee. H the Assignee Sager in tkb uls %!ve, tarns also refers to svch su tin ' For Content end in the seou ent assignee Attar the assignment all rights and benel'rts of theme To d ff`ner makes an assignor®nt Agretment shall belong to and nd be be enforceable by the ASslirrae• The Assignee win notify you when . ?.,., 30VEttE1GN BANK, I130 Berkshire .Boulevard. WyoynissfnX pq 19610 Mon For t:0-SIGN>:R: Any person sit ning the t11v en's To ail sums Ise and to perform 811 a Agreement below promises separately and ?agelher with all Co-Slgner(s} and BuYa to i greamWE in thls•Con#ract Co•Slgner+rili not be ae 0waOr of the vahlole. ? • Pay :R: on signing the Co ppmer's Securityemant,Dabw ?vey e$ a security internal in the vehicle and -agrees For ?leD1er'h au r.o•Ownerisf and ifuyer{s), to perform alt a ?' ''NOMIss to Pay" section. praementr in the Security Agreement and all other parts of this Contract scept the Artfonm Plnant?0d TE Ifs the terns shown In the boxes strove are part of this contract S 23it189. 95 PROMISE TO PAY: You AM to pay us the Tote! Sala Prk:e for the Vehicle D ? We may retch a psrdan of amounts marlted'" Paying g EX the Amrnrntfhsrtced Pm Intarstt.You y king the Cash Downpayment and the Paying EX t due data, You a e to txomha to mate payment in accordance with the N iij the Trsd to gshown above on or talon the. data of al fontact and the I a0k ? Day an other Amounts•trhk:h may Yet Schedule, You Promise in makthe e SW or on or eefare the ssame uk dYou ay &W all rrrorgh as pay send P" to to ' des an 20may to collect aouhmne nts due oundunder th er this Contract ?T or of agree to oil, he Seller or Ass Mb protect or get possea8lon ohe Vahkie. You of s bo to most recenoy speckles in the wrlften notkx to you orP*Mbstthe ? Rrrri(al p agree to make ptc Me &&i l ?ltte Rite miyr Be newtlable wfth fire Sefler. ADDtTIORALDISpQaU MY assign this controrct and may bisclosures:,Before signing ? the ig? Contract b be e sure that ? sure that y: yov recehre the FmsYnce Vhatg Y a Aar#of Buyer and read the DEsctosure to By signing below, we spree to 3011 the Vehicle to you under the terms of this Conill SELLER Ttsars.aod Condlttons: 9arore afff a: this Cord be sure you i Noedra and read the fotlowinZ If marlte0 t wfriptt areAdd%ml pseps to and part of this You ai . coa ®.Tbis Con6act.?ontinup? on the nrv?tse side. • LK) D> bt Can i(etion fairarentaod a'rrro pmtsction) seWrate dd ddWm and 89l NOTICE To BUYER-DO NOT-SIGN THIS CONTRACT IN RLANK. YOU ARE ENTITLED TO EXACT COPY F T CONTtALT YOU SIGN:' KEEP IT TO PROTECTYOU LEGAL.R(G(•(BUYER lsEitU / /a0Es - ? ? Z T BUYER CO-slo;%R& YOU ssOUI.D B&Ap NOTICE 7l'0 CO•SI6NER, AGRZ -8(tiN d, RZAO q. WMCH HAS -Il G TO IrOU ON A 3EPA SIGat CO-SM1191RIS AG NTr You the on or Ri?TS;DOCUMEN'I, tdBFOitB Fact NItnetits inNG TIMthisCCO ontras You intend to ?d penons) si ing below as "CO-Signer," ronum- In uec m: to make this Con bound by all the term; of this Comract, separate And ttog er 1wi the ue t this Cam mat egad to perform all made snl prior demand for payment with n ti;c?• even II we will use the proce? only Ter tho yCt1t honaitt. Yong You era as the promise to )3tryer or exercised our'3t0ar1ty iotorgt, You aL?o 4ckaowlcd a"to par even thopo we may not have V tbCeiving a comptctcd;eopy aCtttis Coottaet Co-3igpec's 3igntitnta SC.LALI ' Address _AEA Date CotiSignar's Sii:aaenrt' (s CO-OWfKgR'g, address SiiCUItI't')f 1113R;$XaCIM y9u, the peon Drrte signing below as "Co pwner," tagothor with the or fter*i,c W WI of thc• mesa' o P WenW M. a ov You agrvc ra be bound by the terms of the Scum* Owners of the ocpt the arxection. You arc givirr; as the :Z ft intrreat to induca n3 Co make thie Contract with tke Bu w, and to Agreement and all the -Paay parts, of the Contract latent the on thk Col ttMeL You Witt ndt be i csponsiblc•for any dcfrcioncy which might be due agar Yet. and to aCCare the P?aeat by thhe NOW of 311 stints due repossmion and•urk of the vehielo, Coco *wnerY SI=naturo $t3AL t?1t?2/fr>iEi ' Address 7116 Pcrsons da?ntn$tselow cxpraer Date ar1sion) •tgiac.i it wa IY agme'to be bound by the arbitration provision in Section 22 on the tav?sida $nch prom alt N • arbil Y re fit on the fiat that they Have read, anders}4? and man to that provision. I="" ONS BIGi" Ili l llt M? in the ND AM AGRR &4AT-DIM l® MAY.E8 23l) BY ARBI' ATI()N IN$Ta`AD OF BY II.ITIGATAvii i q 40[IktT ANDA,C NOWi =G.' THA TAY VE RECill 1A COPY OF S¢V0WGiv 81?1YIC'3 PRFVACY POLICY. BUYER,, CO=SIGNER WND CIS 0NER, IF APPLICABLE, ACKNOWEDOE. RECEIPT OF A C . S CONTRACT AND PRI ?tCY NOTICE AT THE TIME OF SIGNING, INCLUDING THE ADDITIONAL ISG SURE-S AND PY OF US LISTE44 THE SEG N•CALLEb A L TERMS AND CONDITIONS.. PACE • / ? rsur?v- - ?rtstrrt .. . . R$vEASI$ SIDE FOR ylt+I['ORTANT INFOR1GfATION: CO SI6Ndl OR EX10yypgi , rarrmmr fM4rZ3 G1 oRf81NA!-tYaae • eFaiBr 00PY-CanaT•eptRORFR 3/Ce3rnrfERi CaPY. Nnk? COrx. iteldrnrad a Not aiwCON . .. i aFrtYrCr4 ate, •A 11/25/2008 13:49 6098239598 PAGE 08/09 a ? SEGdttttY ADDITIONAL TERMS AND' CONDITIONS AMMEIIT. To secure the payment of an suns due and. dV60 ? unhr ft Cantrac?ye? a t erfonaar>ce s toSoutdo not keep any promise you made in another Contract, Note, Loan orAgr -' 9 aCached to,thaY std irttefeSHn s 4bicta, in all kitlti' I?jGer ir?Ff the ;k MsURi1Ce a?+nYAteaVrw and litany pi s d . YOU mode awn ump?dtndertlda piwsedL The Assigrej amry:ameunladrieend e. You ammiltetl?entin.Mw< forihit:Cvrdracbo". Z r my any of your money an deDesit wetly .This E Yoe any ?ry in h wo this wftei; or Y 'mestly arl" (a naw;ar may In the httmw1be•d(rpotAted with'AIN96e'hy You. withiurtsdlen to docwm so to be IIncep la .or g treud•or d v? any prior naftte yott riesty, or arts found by a court 2 1? & You nlettattkru or (ninlyenc;•prooeadimgs, ot•anyone files bankruptcy' Amount 17nanew am the Is UTft The Tow of Payments is the sun of the insolvency puceedings st . Pr Charge consf?s safely of Interest h. You take in V6111016 oir?e ? Rom Chsw Tht Fnnnce the Weed States or candy mthod our wrhten co compaletl Pop" on dally etr err the LAW em puted on the MU shown all the f 0° balance of the Amount Floofted. The Finance dprge L You use Uu Vehicle or aftow someone dse to use ft in a way that causes ft not to or I4rm bakwe-will receive all caveD? 4Y iwance;•a '.-Cft1 VMX W)dl N. W4 wnl ahargia interrn.on'A.aBY au h aft or Sthat c6d' tl ? to be subject to t? to k= s oasis on' thfi oatstandin or dY govemmeM . is also ?? on earitday of tl?a loan tetmp itlc4idf a g k. The poked ny perbd lay wlrkh a fate Vehitie Is kut stalgtt, deet<oyed or damaged beyond economical repair, the emu poor of The day la' tto the Aiuunl! Pale t6 diMed RW or found W&rt a reasonable ft or pair, and not 1m In that calendar year. &0* epees dui bemuse Interest is cuipbled 4' Anodhei creditor tries in take the Vehicle or your money on depasA with Aaatgrlee by on a lets payuteflla wi8 reauR in addiKeaiai Land, n applicable; a laivJ01910 .1., .. . .. wilt ,b soq ? f bR1a An ll In karat (let olyreed. Early and/or late payments % OUR.R'•f?1w ARE •1N. 3 Pfi?enE t>D chargg+:, DdtA1f Li OF°fjlis t(;y; If you are ii Defatdt of tMs' 4. LAZE iIIIIIRME; Contract; we may entora mry ! IEbfa td kar. MRa days efts its due , a an paymani not made within 10 "ra (n this tbnb act We may 80 Drat may alga do the oft spa?, daysa t: Ae wamttaider ? ;PM ? be 2% pur m on the vnpaid amount of the . another. Some ofthe 11 wero?q do an dhe ?rid at the ea,? time or imatar da late _ dms will be due . a month in IDIOM of 10 days to be a furl a mNb. The a. ACCELERAriail: We can danwmdthat y? in the entire un lmtt = 181111 Is when caned.. Nv late charge win be due if dhe reason that the ., on the Cantrmd and aR unpaid /malice lap Itag balance o 1wM sae, sf6er debut trwenth owMaRdime balaom on.thts coribW is lie peya"? and money oft !due. You due.-No tae obarge ? be ? Nth Pay ???tu)n ore ? agree plat you ft? charge glesed ort art earner °?' ?aaaoa peat,the p?anem iaJafa is because of aJam a ON: We can repossess pre aAen prohibited law. , first ;ATtWI I1?pA PAL _' ihdnOr Y Yleve arquaili parg"4e it for trIkov rdIss nohrftrt law. We can do repleytn) YMEpiSt We win apply Pa1n» is in -the foils ,r i for us You ap" that we can peaueabh c?`orna an tim?emmarA Q(b! trmbrresi; and then to late giac any other tidies found in the V Your property to do thin We the oto k* at we nd the rM for, Papal and any othar•amougts ea eltiehe, but wM (oboe these thi to o)ye hr r tweet the thhtEs batik, You may, you if You ask tf you 6. PREP14Ymum. You may prepay, an fUH or i) A6669 of RePoss -Wort_ if you do not rho 'i$Und • n e Ve our A time without. peeaih i f you proxy. Or ? the amount owed on lids Contract at any we may dbpose of these Mko in the same manner-as the Motor Velikie. You that Unie, time it outedmikd pert; M",% MA" to make may use your Poew lain in ogre a that we peymeatKanrM yob pay AN anaurds,dtarYgad04thit tlotrtra p rePOea?n>t the Velacte pad taking it to a place for stooge mad* reduce fhe number of Mz laments You *1 make. , . Mq; t c: t(OLU Y,. f 61{y: Ws-son ask camriratt 7. S. W ;at,..; * ~,tmi t?YO u:tJ4tYValrisle at a reasenabig XMER 1rSEL1.WAND• f• We a ' c :d{d T' ?' I?+oh}Tr lit hhder this Contract propatyat• sepumlC? for tllb ptee traive U1e right to treat eery without bshmgamy tights sao L llt'6.or4thg. ltidn•and IN other 15 SOME TRIM YOU SHOULD VIOW IF Va REPMM THE VEHICLE: n we re a before t4 cy IN tfue Woout orw to Yd agree to make 0 RaYmarRs on a NOME. +Ne will Mft of R nr g you on we Pa?i your last address we know about wnhout<+tp you In advance. You.ghia up any right you m heve enforce riqu our. rights This Notice tg w1R N-YOU hoK to hula ( )theVethe tot You wiu Ion fats the bala enforce em rfghls some otltar person or may require that we reinstate the Contract: This means You ou war lave to pay the ? ?irt?tr Yoe. Yea sE ire that we mpr ghee tqt oul pup" before ard0^ca dur ?s against Oh_ er amourrla dtte You may the V hte ia an the Contract and ; a16 delupuent hisMlknrnt This You w6 r Ia?ection and fVft 0111111R43011110 Oft all delenaes based o Pmt but not agaitast yar. 'a oft t Q collateral a suretyship and impairment of b. VEOEM 0N: You howthe right to buy-back (redeem) rho Vehicle-within 15 days of INTER!S ITURITY` AND JUI>?BMENT: tutee ea# at trio rate proylded to this mining of pre Ndltx and at ar% later tints before win owl the Vehick. it you redeem the >L Bon IKTER Vehicle. we win deliver the Vehicle to you at a place as provided by taw, as soon as is aorta tsh we *=U* en the u** balance until paid In fill no after olab * reasonably poe?e, but in not Mre'tlurr ten'(10) t u*m days of oar receipt d the funds' after tier A jrdgment aplbst You for the amornds due. This % red cyan M the mquh il. Myoq do not radeK you give up al ubim.to the VIII .matruRy oitum because of aooaienUon. It at any Vale interest as ed for in this rw "'If yrtd dw t a paragraph ! by law, interest shall aborue of the highest rate allowed by "sod to Pay cd* and ex ens Wa *0 301 The recetwo to Yelbt9e money at she *M be tkattime. Y p YOR.ewe,.Ind then to pay the amount you owe on the ix• Y o bit~ 'MR Mm11T INTEREST: You will mot pew d Sl1RPLUS•QR-DEFICIENCr If vwrd it fao 'man latirr'ura b or Other ' in the Vehicle. You wM amok ? ' not enough money from theeaia to-Pay what Yw owe, 8u? will ply Coit to the mee t la pay there Is rtBMs pay leg . Sigreeragre psy what necessary tk' and meitlairt our aecut ity tnteresE in the YOWL You win ascot us is soil ow-10 us aPENSES: xou in hgvwi vtr IithDiyet noted on the I ta•ol•Tft a to tfu•Vahw& You will notseo ferpay the cusha.of repasmgg, *dng: raRahf fl? ffS'anBOno R a Van on the Vehicle, you will the 04P sale and seiline•the Vehlele•rs be ?, pmpftg 1P for the lira,. Raj etion and aggNrod bplaw: There rbsh wig only be due H: 1. ImfavR eitcetds t'ataen?( g9}? da_is at the tbnd•df rept>a„i 10Q YOi1R P 1 ?ptR THE VEHICLE- You will in the Vehicle in- good The auwunt of coals are ac 4 nary and reasonable; and repair. YOU tjmres and hood condition and iNe n.pmre the rests Were .paid. the rh?, You Bte ou.w0 pay leg costs-of maintaining lt;, S=. WNTiM M Ri)IIIA?REPAYMENT AND win reduce f nalabuse the VclN* or p it inyUdng to be done to .the. Vehicle which all or part of the amount *You owe ut1dir 06 REIN without You m prepay fhaa ter normal urea Ind oae. Yomr wJn tact rase a the Vehicle for contract: any nee witiit RnfP caas or Iwo. Vou w -not move the Veitipje from year address ehata? ai'rebate upearaeod'flnance chargers. t? a default andwe s Tepomn yt qw r lr * bf piis'ILWA od to a am Prolanant 0w of ly?hg without' shown ort the we will M isatfoil yoo' to VaY tae >anrourits Yeg otree It to get year +irMio7e bast arid, I YpUit•p?? ABOUT fNSURANi:E: You eAy keep the Vneetuhryde mgusinadvanm.• irzlhstatefHiscantntck I L and P uA a0 sums insured against fire 17. HEINS AIM PERML•R&RESENTATIVES, BOUND: Aft dde us are OW in lint The insurance coverage must be your deap, e. cotttrad shag The hwmni% i ? your. interests and our Interests at'y1e time of any Insured I b tnfarCEable against your heirs and personal representatives of your estate. . '. amY in rat,terp an hrsrireild -con,parry rep" Onim thei".neala Taft h annsduftcma reensemu•to dst rte(i tired irtstmreliux 19. SE11`86MUSly Of This •PROYContract tSDNS: ds H to for be Q flilad to do ky. reason ed any according par Colib in the stale + se part of to tbo-lovj of Pennrl+?arua' Yahfcie is tgira any o V is Cotrtraact 3haR became with at feast 16 P mod. insurance policy mud provide us Illegal; 10id at ilnenforrx;r6ta,fiat'pertshaq riot tie a part of this Contiect days - prior Witten notice of an aancellatlan or reduction in co,raraRe Om 2Q itSSt611MlNlt` BY BUYER: Buyerslnlil'not asaige this tatrrtract n9u you,shalt tht Po ft or other eyrd:nca o f'•inuy me gage to ut.ln -the . 21, THERE ASIA NONARRAIMU* BY SEUjK event of the IaOBe aquga b g Veldcl, you WE Immediately notgy,us in writing and fle s WARRANTIES QF MERCHANTABILITY 41111 FiTN? E E Alp TICq? P Post THE. Proof of less 011th pre iriwrer. UNLESS. WE HAVE OJVI p YOU A SM W(AiE iRrITEM e. OUR RIGHT TO FILE PROOF OF Uft In the avant at any loss or damage to the ENTERS JXTO A SERVICE CONT1tACT WITH BUYER fff 90 AYS FR AtMTHE ATE OF am. R Ve d )K ;Or mfuaa tit ft a cl*n or-woof of loos web she Insurance cornpan WITMi190 DAIS FROM THE DATE OF r?rea 101 LAulgrieN at y autherized b y yav iH15 COt(iRACi; . ; of theot { ?7y Ple a PW of aubeogmrent aasiMs:a, of an p Ya o#•any 7Z AR81TRJtTlON: a your Apes With wit the inpuni ce oompanf4.fh your name and acting a, Yau and we 4 rasped tow ft framd claim. You agree that You de net have the ' agree that uto-o f pa .elect to arlsoe • rrquire the other party hinwgim 20 w14 not evoke the pour you to arbitrate • any dairirvr disputeflf r riatare that t a arises from. or relates Inary way'ta us to (He a proof of loss, You agree ee that we may this aaarcise th>f Contract It we or u power for our benefit and not for your benefit, loextept ss, Y as agree in this yo choose arbitratfvo with respect to a claim or dispute, neither you )ontraot and by lax rror we will then have the right to Btfgate dust clakn in court have a jqry trirl on that claim, or b. OUR F! To END (NsUliat'NCE CHECKS: You agree that the-Seller, Assignee, partiapate in a class acnam suit or Priyata sportily g©neral action; If 10 Subsegw'At 4salprrea, or an adthvrt'aed employee of any of them 1"we") may any wsa veur TL. ..:, .,. you or we choose. to .._ arbitrate a dispute or claim, the party choosing to arbitrafe must give the other natirrs to 11/25/2008 13:49 6098239598 "11:p18Ca 48'fQilipe3r; vrsnr'opnr?4? n ra'oaonoma afq Te o?rrm 7am°snsrnn-n1en erihirTA7btfiaPAGE lC?bQ?a099n 09 d1haR of this .Contra IL otleivlse,' we will ep the inWUelice piocaufs to reduce the unpaid P.D. Box 50191 335 Madison Avatars; Flom 10 (Pleri? rt a uhf Aftarthe bahrtcedue us b arty emhxss wM bebrM t0 you ' ? . 12. R ON" IF YOU BREAK YOUR •PROiNISUPOUT-W IMURLTY INTEREST, Mlnneapol MN 654050191 NOW York NY 10017-4608 1-80Qr4T4. 1?800?52 5 267t ' VENN3 E OR N15tfRADC * If you fag to keep your pt^anh a tc pay 1110g tees, tames, hens or the cost t k ' , ? wtinr.artMtrafien.forum.o?ar AOud[8>Y . s sthacuaary o sep % Vehicle in good condition and repair, we may advance any " money You promised to pay. If you fad to keep your promises about required Insurance,-we may sdvaencemotte?m obtain Insurance b cover lea or damage b the Vehicle, we ban the You may obtain the arbitration rules by contaott ft above administrators. Thera shall b one 0rbibator acceptable to the pantos; Tha arbitrator shall be Independent and unrelitld t l If u i d f choice of•wha her or net io Advance any money for.theso purposes. Such luauranoa will be Iimbd to on amount not greater than you owe on. this Contract THE INSURANCE WE PURCHASE MAYMESN NIFICA t Y MORE E IVE you or as. are an yo n lV duet us ot the Vehicle primarily for personal, family c , itousebohi use, wt ftee that wo+w7pay the first $100 Imfiling and adminBtraHve fees 9 yo wish to !abate arbitration, . ' . XPENS AND PROVIDE YOU LESS COVERAGE THAN INSURANCE YOU COULD PURCHASE YOURSELF. We wit add poy money we advance on your behalf to the balance on which we Impose c. Any demand for arbitra6aat must be made within the.appfrabla time limit which woul apply ethe damn WV in court. •: •• rj; YOU AffD beLGft1 Y1SMD'GIVINf;`UP iWITS TO RE501 V Rnanot Charges at the Annual Percentage Rote of this Contract You agree to repay the money advanced as we shore may spa*. (a Immediebdy.on demand, or (R along with your , CERTAIN CLAIMS IN CDURi AND HAVE A JUDGE OR JURY DECIDE THE CASE YOU ARE ALS GIVING {jP RIGHTS TO PARTICIPATE IN A• CLASS ACT10N EITHER -IN COURT OR 1+ monthly paymobts. If we On= to allow you to re y the money advanced along with your monthly pay prat we can ehoome the amount of these paynwnti and how long you have to , ARBITRATION. a Even if you or we start a claim or depute in court the other can have it moved i repay. If any aj qur In this pampph• are not pAnnitted by law. wte 30 have the ottrer lights deal peymenta an your behalf will not cure our failur f t , arhibatiat. IMPOR FO I y e o per orm your p amuse in this ContruL 23. TANT IN RMAT ON A00t1T PROCEDURES FOR OPENING ANEW ACCNV. 1 help the government fight the fundbhg of terrorism end money laundering sotivitia% Feder, 11 DEFAULT: In this paragraph "You" means the Buyar, CaSigner.and Co.Owmar, or any one of therm. You wit be in "Mui' to the. Contract IF my one or-more of the 101lowing things taw! requires all financial institutions to obtain; verify, and rboord hdbbnon that Identhk each person who opens an account happeh>: • a. 'You do not MAU any paymenton or before ff is due; ar • b. You do not keep-any promise you made in this Contract; or What this means for you: When you•tspan an•account, we win:ask for your-name, address, do, of birth, and other int mialion that will allow us'to ddeteliry you.-We may also ask to we yet d i r vers license or other identifying documents: Buyer's Guide-Window Sticker. U the'CaT'which'Is described on the face of this -Contract has a Buyers Guide -Window Stlcker.required by the Feden Trade Commission Used-Car Trade Regulation Rule, the fslkawing notice•appiles: The information you we on the window form for this Vehicle Is part of this Contract. Information on the window fofm,overtidos an contrary proviSitluts In the eontritcli of salp. NOTICE-ANY HOEDIM'OF THIS'CO?ISit?MER'Ci DIT CONTRACT IS'SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COOL ASSi:RT AGAINST THE SELLER OF 6000S 02 SERVICES' OBTAIREb•PURSUANY HERETO OR WITH THE PROCEEDS HEREOF RECOVER HEREUNDER BY THE DEBTOR SHAI.L NOT EXCEED AMOUNTS PAID BYTHE . DEBTOR HEREUNDER. IAOTICE•OF PROPOSER CREDIT INSURANCE The udgnerts) of this Contract hereby take(s) notice that Group Craft Lite.lnsurenae covemp or Group Credit Accident-and Disability Insurance gage wig be applicable to till Conbact 9 so marked on the front of this Contract, and each such type of aovem win be written by ft insurance company named. This kaunnce, subject to acceptance by do Insurer, rovers only the pomen or persons sigrdn the raq??st for ankhinsurance. The amount of charge is Indicated fm each type of Cmdit Insurance to be purchased. The term t fnsurarhc? commence as of the data the Indd ness is kn:umad and will empire on the original scheduled mtWdty4* of the WdlgedW0 toby the insure and ,AthBi days, then will be dotivemed to the Insureds 111 at6gloata of insurance more fully describing the Cnsumnics. In the •OvaM of p meat' the indebtedness, nefbt d of lnerru?oe charges wg1 be meta when due U n rile 11 of ties hhseral, credit Fite Insurance pays the soW*d unpaid partW the Ameurt arxhd. baring the d(sabtitty c the f gmrad, and aebjed to any benefit waiting perio cA a a- health (dbabilif'•1nsFirand0ays the scheduled monthly payments. Credit life insumme Is based on th origlrnal peymentsehedule. ,.. _? NOTiC:Ii:.•SEE OTHER SIDE FOR IMPORTANTINFORMATION. TIRE PWASION BELOW IS R9f PART OF THE PENNSYLVANIA-MOTOR VEHICLE INSTALLMENT-SALE CONTRACT BET11tEEN'THE RUYEk•AlM SELLER. it, induce u,the "Ass! ASSIGNMENT ye ghee identified on.the'face of this Contractor as follows. Vita" the wldgn Canes the Seder hereby warrants and represents, and cmdinues to warrant and re; Wtnd. state and local 1=1 and rogulations, inchWing, but not limited to, Article 2 of the Pennsylvania Unlfw .sand VOftfoh 001401141 thereby Is absofgta, free of all liens, encumbrances and security lnjam#e, and is s Se V%,= thereon are not ftrgoe a, arose from the silo of the Vehicle therein descrihe'd, and all p shfole extra egWpmerd is oom b and wrrect the cnsh dewnpayment and/or trade-in allowance checl iii, ? crew advanced by us to Buuyer or rebates or. similar payments from us to the Buyer (hot WIM490 and sdg0ntarts than:fn are true; there is 0*9 thereon the Amount Frnanoed iwintorest at undo' the Peamsykolth Motor Vehicle Sates Finance Act and have duly ccomplled with all requirement; aced vitlr any pf jeer faderd or stab law, rot: or gu?on appficablerto tit Contracft a Major Vehicle title eppfbgl fat pstlrapprti?rr the reg?ation of the Ynrchiolb has not been suspended and the Setter knows Pernegfvmh Meter Vehicle Financial Respaisitsilly Ar# the Buyerts) named-In -One within Contract is sit 4VWX is hurl affixed i0.this Cmnbw# ynd Seller has m asrasrr WV of facts Ins airing the vagdN breafrlrF ny titre, Seger shall repnrchm said Contract from Assignee, on demaK actuRl payy:the rem64 s be cumulative and not exoluft and shall not affect any other rim or remedy that Assi nHwss to make any payment due hereunder on the assertion, either oral or written, that the Vehicle is dl my s or service agreement of Seiler at manufacturer, Seller agrees that, on being advised by As 1ssd7o for same irmaadietely in sorordarme with the repurchase terms sot faith below, and *w the a fees,.a0ft end expanses incurred in defending against claims asserted by Buyer and motrals insu and that l -the slap comparable teens with aallopler bnorLmWo theny on the half of the.B yer. if Serer Tied unable-to to he Euyer in obtafaiag replacement insurance for the unexpired period of the-original insurance. issigns and taceptlrrg payment for k Sder.aufholtes the Assignee to act as the Seller's agent otpr tti no hi cash, the.6 ight have at-la, ? not a of such claim further agrees IUg atatrns far do so. r. By a igeprerat lip MIIWt trce• Asaigthse who parplrasad the Contract and/or teethe purpose o signing senees name to this, withcyt.thwSellars sip,nshim. Assignee may exercise Un power given in this paragraph forthc benefitof thrAssigrsea and not and i greet nit tie remake the power glean in this paragraph. III dale o TM the 'Y! TM -# -A MA - (NW. eCo am r owing tuaraon, a mptrurd•as•set forth below, and of in 04trrtjr sgakut Seller. In -the event that Buyer fans id brfihe Buyer by Seger, at that Seibr mftaes to hm uyer Senor will JOW'diose the Costract from AUW old lea harmless from anY other ciakns of Buy id of payments nphde by Buyer to l nee. If the Sal r tc no schoulukat expiraion date, rarill attempt uyer end pay to IlMra odditionai co* incurred the C100tiock as Sang, delivering-the Contract to i Of 00r t. w dwut recowursea, he Asssig AssigneeentIs degre e benefit of VwSener.*Seier does not'have the ft M allay Is required by this Assignmert to repurchase thirContract and/or Vehicle. Seiler shall pay to Assignee, in cash, the full unpaid batat(ce of the Contract as of as any than earned fRrranrce Charge and any and an costs and ismpartaea paid or Incurred in respect thereto,. icing reasonable attorneys' fees, ,b y or against any Buyer, Owper or persons in possession of the Vehicle end/or by or apafnd r. Wier hereby s00s, assigns and transfers unto the Assignee, its suceceassom and ass! I, an moneys due and to become due thereunder, and In and to rite Vshlote therein described, with N power in the.A a In Its.or Se]iet creme -.1ml or other actin whkfi Seller might have token ss rites Saner marks sitter of the: endorsements below, tftfed 'WITH FULL RECOURSE" or 'WITH REP ASV SeOers aftriment shall, except for thu provisions sttghtment" be without recourse. tSE?-Spier agrees fleet {n addfflan to the paragraph above tlUed "AsAignmarr?" in the Event of OeleUlt by Buyer in the fun parnept on the due date # met oft ?r tea Corhtraot or In.the prompt performance of any other ohp? on to be pertormed under the Contract by Buyer, Seller will, on demand by Assignee, forth tiro m Asenigrnae fora repurehime price, in cash, consprrted as satfarth above. Saner r a if the Veld is ?n to the provbfons of the panttraph above tinrxf °Assfgnment," In the Event of any Dehutt•by Buyer Which shall entitle Assignee possessed by Assignee and delivered to Seflar, and without regard to the then condition of the Volikle, forthwith repurchase w /..uw AwnIN„M fn? • wsn„rnl,aba nrhna r.1 MYr, ,wwn„#..i M ...+ Fwr+h aewua to the Code r?i163b of the AB. uyer as site Will ill unit to are of fug age and led capacity rto controcil; Ily received and no part thereof consisted of ?y s orgUWta ad or a part of the i ?1ap RRab of the Contnrot sel: forts therein; we act to Una transaction and with the federal Tn g a lien or anoumt nom In favor of Assignee h !'may -result in the suspension of said ngm knbww to the Seller to be-the same Identical Contract If any swch warranties or momearti .? do d CJ ra co ? V) tT?l C D L-1 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff No. 69 vs. PREETHIKA FAROOK CIVIL ACTION Defendant(s) ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Plaintiff, SOVEREIGN BANK, in the above- captioned matter. AMATO AND OCIATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Dated: March 13, 2009 C= ` n c= - r7i CD =A 7 CD -?C G --j Sheriffs Office of Cumberland County R Thomas Kline tr et'C umbrri Edward L Schorpp Sheriff C611111 ?+6 Solicitor Ronny R Anderson Jody S Smith Chief Deputy Or'cE F E-E s-ERtF:F Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03124/2009 03:14 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 24, 2009 at 1514 hours, he served a true copy of the within Complaint and Notice upon the within named defendant, to wit: Preethika Farook, by making known unto Preethika Farook personally, at 102 Novembei Dr., Apt. 1, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to hei personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, March 25, 2009 R THOMAS KLINE, SHERIFF Deputy Sh i f Docket No. 2009-1708 Sovereign Bank v Preethika Farook N r-; Lu k r - j y ? a^y - C' a COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff : No. 09-1708 Civil vs. PREETHIKA FAROOK CIVIL ACTION Defendant(s) PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Pursuant to the attached Stipulation of Parties, kindly enter judgment in favor of Plaintiff and against the above-named Defendant as follows: Debt $25,044.43 Total $25,044.43 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE ATTACHED STIPULATION. Dated: May 14, 2009 AMATO D ASSOCIATES, P.C. By: onald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff No. 09-1708 Civil VS. PREETHIKA FAROOK CIVIL ACTION Defendant(s) CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named Plaintiff is: 1 Sovereign Way Providence RI 02915 I do certify that the precise last known address of the Defendant is: 102 November Drive, Apt. 1 Camp Hill PA 17011 AMAT D ASSOCIATES, P.C. By: onald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff No. 09-1708 Civil vs. PREETHIKA FAROOK : CIVIL ACTION Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON The undersigned, being duly sworn, according to law, deposes and says that he is unable to determine whether or not the above Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of The Servicemembers Civil Relief Act; That Prethika Farook is over 18 years of age, resides at 102 November Drive, Apt. 1, Camp Hill PA 17011 and is employed; Sworn to and subscribed before me this \kp day of c? 2009 A.D. ?s 1 NOTA PU NOTAR:AL SEAL GEOFFREY G SCNOENECK Note y PUNIC HANOVER TOWIGINIP, NOWHAMPTON CNTY My Comadaloe F.xphM Wroh 20, 2012 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff vs. PREETHIKA FAROOK Defendant(s) No. 09-1708 Civil CIVIL ACTION STIPULATION OF PARTIES FOR ENTRY OF JUDGMENT IN FAVOR OF PLAINTIFF AND AGAINST DEFENDANT The Plaintiff, SOVEREIGN BANK, by and through its counsel, Amato and Associates, P.C., and the Defendant, PREETHIKA FAROOK, by and through counsel, Law Offices of Robert M.Walker, LLC, hereby stipulate this !3 day of 94 ",- 2009 as follows: 2009 1. That judgment shall be entered in favor of Plaintiff and against Defendant for $25,044.43 by agreement of the Parties upon Praecipe by the Plaintiff. 2. Subsequent to judgment being entered, as provided in paragraph 1, Plaintiff will forebear the filing of a Praecipe for a Writ of Execution on said judgment if a total of $18,616.83 is paid. The total amount of $18,616.83 shall be paid in regular monthly installments with an initial payment of $100.00 due on June 10, 2009 with subsequent equal monthly payments of $100.00. All future payments shall be due on the 10th of each month thereafter until a total of $18,616.83 is paid. 3. All payments due under this Stipulation are to be made payable to "Ronald Amato - Attorney for SOVEREIGN BANK " and shall be forwarded to Amato & Associates, P.C., 107 North Commerce Way, Bethlehem, PA 18017. 4. In the event that Defendant fails to make any of the above payments due under this Stipulation when due, and said failure continues for more than fifteen (15) days after the respective due date, Plaintiff may, without notice to Defendant or its counsel, immediately void the settlement reached between the parties and file a Praecipe for a Writ of Execution to recover the full remaining balance of the above judgment less any payments made under this Stipulation by Defendant. 5. Upon the clearing of all payments, as provided in paragraph 2, in a timely fashion by the Defendant, Plaintiff will promptly satisfy the judgment entered of record. 6. Plaintiffs compliance with Pennsylvania Rule of Civil Procedure 237.1 is herebX excused and waived by Defendant. 7. All parties acknowledge that they have consulted with - or have had the opportunity to consult with - legal counsel and that each knowingly and voluntarily enters into this Stipulation. Sovereign Bank By: R nald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 Robert M. Walker By: Robe o. Walker Attorney for Defendant 3461 Market Street, Suite 103 Camp Hill, PA 17011 Preethika Farook By: 1p, ree 102 ovember Dr., Apt 1 Camp Hill, PA 17011 FILE U l%'= OF THE 2009 MAY 20 FHA 12: 52 V f" jL 14. oo po A-ny C,u,''a(v 19 CIA Rx* as s44C Alm "at" COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff No. 09-1708 Civil VS. PREETHIKA FAROOK Defendant(s) : CIVIL ACTION NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE NAMED DEFENDANT(S) IN THE AMOUNT OF $25,044.43 ON M y ao , 2009. () A COPY OF ALL DOCUMENTS FILED ITH THE PROTHONOTARY IN SUPPORT OF THE IN T IS/ARE ENCLOSED. OT Y - UMBERLAND COUNTY Per: If you have any questions concerning the above, please contact the undersigned. AMAT D ASSOCIATES, P.C. By: onal Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1708 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SOVEREIGN BANK Plaintiff (s) From PREETHIKA FABROOK, 102 NOVEMBER DRIVE, APT. 1, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CASH ON HAND OR IN THE POSSESSION OF THE DEFENDANT(S), ACCOUNTS RECEIVABLES, FURNITURE, FURNISHINGS, EQUIPMENT, INVENTORY, TOOLS, ELECTRONIC EQUIPMENT, VEHICLES, ANY AND ALL OTHER PERSONAL PROPERTY BELONGING TO THE ABOVE-NAMED DEFENDANT(S). (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SOVEREIGN BANK, 3556 GETTYSBURG ROAD, CAMP HILL, PA 17011 - ALL PROPERTY OF THE ABOVE-NAMED DEFENDANT(S), INCLUDING, WITHOUT LIMITATION, ALL SAVINGS AND CHECKING ACCOUNTS, CERTIFICATES OF DEPOSIT, MONEY MARKET ACCOUNTS, DEPOSITS AND ALL DEBTS AND OTHER PROPERTY AND/OR OBLIGATIONS OWING FROM THE ABOVE-NAMED GARNISHEE TO THE ABOVE NAMED DEFENDANT(S), INCLUDING BUT NOT LIMITED TO ACCOUNT #2331055696, AND ANY ACCOUNT OWNED SOLELY OR IN PART BY THE ABOVE-NAMED DEFENDANT(S), WHICH ARE IN THE POSSESSION, CUSTODY AND/OR CONTROL OF SAID GARNISHEE(S). 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$23,744.43 Interest $4,108.57 Atty's Comm % Atty Paid $165.50 Plaintiff Paid Date: March 23, 2012 L.L.$.50 Due Prothy $2.25 Other Costs C;?4? David D. Buell, Prothon tary (Seal) By: Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff CIVIL ACTION NO. 09-1708 Civil vs. ? ?13 y ?r Amount Due $ 25,044.43 a3 ? ( . PREETHIKA FAROOK )oa V a ; Interest $ 4,108.57 -- ,4k Defendant(s) 1 l7 ct? : Ca„ tail Payments C t $ 1,300.00 $ cz? - os s r n =rte '-'- Sovereign Bank Poundage $ ? °c Garnishe e ?> w q a MIN Total $ 27,853.00 ? -_ nn,^, > C) --? r-n To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION AND ATTACHMENT IN THE ABOVE MATTER. PRAECIPE WRIT OF EXECUTION Issue a 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) All cash on hand or in the possession of the defendant(s), accounts receivables, furniture, furnishinas, equipment, inventory, tools, electronic equipment, vehicles, any and all other personal property belonging to the above-named defendant(s). PRAECIPE FOR WRIT OF 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: All property of the above-named defendant(s) including, without limitation, all savings and checking accounts, certificates of deposit, money market accounts, deposits and all debts and other property and/or obligations owing from the above-named garnishee to the above named defendant(s), including but not limited to account #2331055696, and any account owned solely or in part by the above-named defendant(s), which are in the possession, custody and/or control of said garnishee(s). Q,uk 9.00 el ?tl? 41.Sb F '1$. SO u n 14,aaa« ti sD?a a4? AMATO LNDLESSA, P.C. BV' Ronald Amato, Esq., Atty 0-#37323 Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff Attorney File#: 2084752 107 North Commerce Way a, aS?Q Bethlehem, PA 18017 so LA- (610) 866-0400 +:S1 (,OSga A DEBT COLLECTION LAW FIRM 2-4 019S 1 (o W I l ? CAF & 1';t? <" /),,a ?l SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy r ` 12 M A R 29 AM 10: u Richard W Stewart Solicitor ,!JMBEF,L'A ?IaLil 4.. PENNSYLVA=NHA Sovereign Bank I Case Number vs. 2009-1708 Preethika Farook SHERIFF'S RETURN OF SERVICE 03/28/2012 12:06 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2012 at 1201 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Preethika Farook, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Denise Beecher, Customer Service Representative, 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. SO ANSWERS, 7 March 29, 2012 RON R ANDERSON, SHERIFF it lam Cine, Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff vs. PREETHIKA FAROOK Defendant(s) No. 09-1708 Civilr I C-) CIVIL ACTION Sovereign Bank Garnishee C JJ INTERRO ATORIES TO GARNISHEE To: Sovereign Bank, Garnishee 3556 Gettysburg Road, Camp Hill PA 17011 You are required to submit answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a judgment being entered against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? NO 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? YES, SEE ATTACHED 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? NO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? NO 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? •r'n m e-:7 (7 NO 6. At any time after you were served did you pay, transfer or deliver any money nor property to the defendant or any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? NO 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. NO 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S.A. § 8123? If so, identify each account. NO 9. At any time before or after you were served, did the defendant, either solely or in part, have any account (savings, checking, certificate of deposit, money market, deposits or any other debt and/or property) [including but not limited to 2331055696] with your office? YES, SEE ATTACHED 10. If your answer to interrogatory #9 is in the affirmative, state: A) the account number of each account; B) the amount of money in each account. SEE ATTACHED AMAT ESSA, P.C. Ronald Amato, Esq., Atty ID #3232 Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File#: 2084752 ANSWERS TO INTERROGATORIES Account # 1791053483 Balance: $0.00 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $0.00. Account Holder: PREETHIKA FAROOK 3526 SEPTEMBER DR APT 6 CAMP HILL, PA 17011-5065 VERIFICATION I, John S. Gomes, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. n Bank By: John S. Gomes C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: SOVEREIGN BANK VS. PREETHIKA FABROOK CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows. Ronald Amato, Esquire Amato and Associates, P.C. 107 North Commerce Way Bethlehem, PA 18017 Service by certified mail addressed as follows: PREETHIKA FAROOK 3526 SEPTEMBER DR APT 6 CAMP HILL, PA 17011-5065 John S. Gome% C.O.P. Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 April 5, 2012 COU%T OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK Plaintiff No. 09-1708 Civil vs. PREETHIKA FAROOK ; CIVIL ACTION rte- Cn <--" ' r- Defendant(s) CD >C: .. Sovereign Bank r? Garnishee PRAECIPE TO DISCONTINUE AGAINST GARNISHEE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please discontinue the above-captioned matter against Sovereign Bank, Garnishee, ONLY, without prejudice. AMATO AND LESSA, P.C. By: . k " l<::, Ronbfd Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM 4450 PQ A-MY ct3l7gl5 L,A-a737ay SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,jy R Anderson ieriff Jody S Smith Chief Deputy Richard W Stewart Solicitor •r c F..-qt.; 2017 JUL 25 PM 12: t<:? CtIMSERLAND PENNSYLVANIA Sovereign Bank vs. Preethika Farook Case Number 2009-1708 SHERIFF'S RETURN OF SERVICE 03128/2012 12:06 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2012 at 1201 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Preethika Farook, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Denise Beecher, Customer Service Representative, 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. 07/23/2012 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiffs attorney. SHERIFF COST: $230.75 SO ANSWERS, July 24, 2012 RON R ANDERSON, SHERIFF 02 ...SD L? ./? Ot ::cuo y dr Shgr Fr rr; o.,oft. In,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SOVEREIGN BANK ';j EU-OFFiGE ti} ICE PROTHONOTARI Plaintiff No. 09-1708 Civil 2012 JUL 26 PM 2: 42 CUMBERLAND COUNTY PENNSYLVANIA VS. PREETHIKA FAROOK Defendant(s) CIVIL ACTION PRA KCIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please satisfy the judgment entered in the above-captioned case. AMATO AND LESSA, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM A Ala a???; -."