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HomeMy WebLinkAbout09-2156IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CARMEL FINANCIAL CORPORATION, NO. pq - S6 aiV IN CIVIL ?CITION Plaintiff, VS. GLADYS E. HARTFORD, Defendant COMPLAINT CODE- FILED ON BEHALF OF PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: II VICharles F. Bennett, Esq. PA I.D. No. 30541 Joel. Hausman, Esq. P I.D. No. 42096 APPLE Al' 1D APPLE, P.C. Firm No. 719 4650 aum Boulevard Pitts urgh, PA 15213 Telepho e:412-682-1466 F x: 412-682-3138 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CARMEL FINANCIAL CORPORATION, NO. IN CIVIL ACTION Plaintiff, VS. GLADYS E. HARTFORD, Defendant NOTICE TO DEFEND 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 appear a personally or by attorney and filing in writing with the Court your defenses or obj ctions 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 otter 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 HE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS BE ABLE TO PROVIDE YOU WITH INFORMATION ABOU THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PER REDUCED FEE OR NO FEE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1800-990-9108 FFICE MAY AGENCIES )NS AT A 2 COMPLAINT 1. Plaintiff is a corporation having offices at 101 East Carmel Driv Ste 205, Carmel, IN,46032. 2. Defendant is an individual whose address is 3780 Spring Rd., TRLR 3A Carlisle, Cumberland County, Pennsylvania 17013-8785. 3. On or about March 3, 2005, the Defendant was granted a loan b Plaintiff at the terms and conditions agreed upon by the parties, as is more specifically shown by the parties' Revolving (Open End) Charge Agreement, a true and correct copy of which is attached hereto, marked Exhibit "A" and made a part h reof. 4. The Plaintiff avers that the agreement between the parties was based upon a written agreement which the Defendant accepted by using loan to make purchases. 5. Thereafter, in breach of obligations under the Agreement, the De?endant failed to make payments as they became due. I 6. Plaintiff avers that the terms of the Agreement provide for acceleration of the entire balance due and owing upon Defendant's breach of the Agreement. 7. Plaintiff avers that the principal balance due amounts to $4,622.70, as is more specifically shown by Plaintiff's Statement of Account, a true and correct copy of which is attached hereto, marked Exhibit "B" and made a part hereof. 8. Plaintiff avers that the interest has accrued at the rate of 17.90% her annum on the balance due from November 25, 2005. 3 9. Per the term of the agreement, the Defendant has agreed to pay tp the Plaintiff as liquidated damages, the costs of collection, including all reasonable attorneys' fees incurred in the collection of monies owing, which Plaintiff avers will amount to 25% of the balance due. 10. Although repeatedly requested to do so by Plaintiff, Defendant h?s willfully failed and refused to pay the amount due to Plaintiff or any part WHEREFORE, Plaintiff demands Judgment against Defendant(s) in the amount of $4,622.70, with appropriate additional interest from November 2?, 2005, plus i attorneys fees and costs. APPLE AND APPLE, P.?. By: Attorneys for Plaintiff(s) 4 .NE(iCH+A,NT1INFORMATION PLEAS! PRINT N e 1?t? (t ? 4 t Piste pint rt6ant code ?Address 3so5C,r-e to k??1 (j Pleee, pi* p City ?!n 0-,r _ State 1 w _Zip h?13k pke,c pier ;BUYER th/E?4)&&WJ'l0 _- PLEASE PAINT Name r c, r ,J i V' a MnK Mid& hi4M l.ut ?4- Address r2 L( tV , t? !Address A - } 1 Pine put ,p ? i ( City G IN.), L4r__ _ State Zip Fr.w o,.t j Phone Number ( 1") ) L(,fr-5 4)1 6 `Phone Numbcr (" l I) ??-) - 7= 5 `3 3 .Cell Phone Number( ) THIS DOCUMENT IS A CONSUMER CREDIT DOCUMENT 414-AN igning this agreement, you choose to buy the goods and services listed below on credit and agree to pay the amount fin ced plus CE CHARGES according to the schedule and terms shown on the front and back ofthis agreement. Ifthis agreemen is signed by a buyer and co-buyer, each is individual)y and 11'ointly responsible for all terms of this agreement. SEE OTHER SI E FOR ADDITIONAL TERMS AND DISCLOSilRES. enle ad andel twmba REVOLVING (OPEN END) CHARGE AGREEMENT Upon our acceptance of this agreement, we will charge the unpaid balance to your new account. You agree to pay $ e'on.vr before 1 and the same each month thereafter while a balance rentalns . YQV itq?Si4 our m it 1) payments include a FINANCE CHARGE of 1.6583%'pee00 Ib (A t Perce tage Rate 17.9%) computed by applying theinonthty periodic rate. tilt: k" Dsily B ance of your account (including new purchases). To_get th'e Av rag, ilyrj3?et, we to a the beginning balance of your account each day,, add any'nt`tf ft Ab ra#S to fees, re met payment fees and annual fees, then subtiael any payments or credits. This gives us th daily balance. We add all the daily balances Jol• the, billing cycle together and diWe by th tota'. number ofdays in the billing cycle. This ilk$i usthe-AVerage'Dai1y'13MCb. ('Aafl TRlCG I I t t ?.. -- f - -? e Dmcn ?O MUS TAX S `t l l tt1T41. LASH PRICE S _ PAID WITH ORDER I AMMST FINANCED $ _I I..IT -_- t:,.•.:.. f 1 t0 ADDITIONAL. PURCHASES: Additibeal pi ollttCisiiridaemcietonti?r?se?}frottrns All be added to your account. Wher1 additional purchases are made, the minimum moripgy jtsywlt)$ :b!l.&;( Lkew d F>?j I NOTICE TO BUYER: 1. Do not si.Sit#iS ' ms any 9, lank spaces. 2. You are entitled to a completed copy of this agreement. 3.Stn- ce 1t tts is a revo vmg`1 credit account, by paying extra Imounts you will save on FINANCE CHARGES. 4. Keep this agreement to protect your legal rights. 5. You acknowledge that you have read and have receved a copy of this agreement. You also acknowledge receiving two copies of the notice of cancellation. YOU, THE BUYER, MAY CANCEL THIS TRANSACTION AT ANY TIME PRIOR TO MIDNICHT OF THE THIRD BUSINESS DAY OF THIS TRANSACTION. SEE THE ACCOMPANYING NOTICE OF CANCELLATION FOR AN EXPLANATION OF THIS RIGHT, ycr Signature ?ere "Dell Co•auyer Signature --- -- D tc 4 Merchant Cor pang Nome • please print Salesperson's Nsme • please onat podiroE Cemr Eau ial Coepo rbe, Ine. 101 1 Eau Carmel Camel. lndiau e/0 1.800.727 2987 Company Original - Whim C ustomcr Copy - Yclluw Merchant Copy- Pink Rev 4132M EXN1811? PDF created with pdfFactory trial version www.pdffacto com REVOLVING MAiAGE??tFT1I. ADD M AND DISCLOSURES 1. DEFINITION OF PARTIES: to this ashhmgheot she weeds "you•', your". and" Zoun` mean the Applicant or Buyer and the wads "we",-one", and ghean Qumelirrenciaf Corporation Inc, PO Box 1127, •CthnuH; Indiana 46082, the creditor on your account, "Seflef' or 'Merchant" is an indepwndmt mwlrxu.'l company, 2. CREDIT LIMIT: We will establish a credit limit for you which we have the right to raise or lower. You may not charge purchases to your atxotmt if it will (cause you to exceed your credit Omit, or if your account is dehrtgaent. 3. PAYMENT TERMS; You eon repay any at all of your scoewn balance at say time without penalty. When you you , M in do sot pay make a miaimm payment Ncb snowah. The amount of the mind mt payment will be the initial nwnddy ;ndteslYd an f+aatof this ag?went. The minimum payment ahtoaue will rennin the place each snccwive month uhttkas additbnal pthrchaw eve + dieted an the Oven of Ibis sgroeoett g no will be applied tint to any unpaid FINANCE CHARGES. 2nd in late charges and service fees, 3rd w the principal balance, and hurt to carry new purchases. 4. ANNUAL FEE: A service tae of 520.00 will be applied to your account each year beginning on the anniversary date of the execution of this agreement S. MONTHLY STATEMENT.- We will mail you a statement each Cionth at the addmp we have for you in our reetads. This statermn will make, lee charges, insuBoien check charges, the begmmol; and Aiidg betas= on your aacowt, payments received, the amount of any f ad the rdeimmn payment that you owe. C RATE: The Monthly Periodic, Rave of Flesom Cilm Is Lf (coitapouring Annual Peneeuhage Rate or it.9%) 7. CALCULATLON OF FINANCE CRAR"i "be ieraad beginning on ths.40 of socepumor of ten agr?eettwm by aL When a It "opened, it is calculated b)t ;papa rig t a'mv pmsdia test to the Avemgs Qt lislpeROt Per acsowte {itWUd'etg new To gq gee Asesape Daly HalanQ we take the hop g 4noe of your aeaomn each ?, add Icy new pdrobit" , lar fame. eewrwg'eaynam tap and annual of kai the p?yht?11EI? This gives us the dail bahmpsp We add ax the qny bslsuocs for the biniog cycle together cased divide by the utai lays SOS mY Thifghm us the Ave mgr Duly RaWies. L SPECIAL CREDIT PROMOTION PLANE; Notwithstanding any.dwn provision of this agreement, we may ucaaiornlly, at our option, offer special credit p Some of three 'al eadit hem igcluda, hW are not Omitted b, the /bllowiag: ( )Maned Payment: Your 6m paym"I is deferred for a specific titan 'od, however, will be asotaaed for the de&rted eeriod• (b) Seats Ai If dta, a speti6ad time period you pry in O tt the amouaI of ywr on made under this peeled stadia sn, no wt7t be tust?ed on those pwdtpx However, the minimm monW}y pymem ;sense still be made no the Some As Cat time 9. DEFAULT: You will be in default if: (a) you fail to owar a ;captured payment when duo on two occasions wit tin any "12 month period; (b) you we declared insolvent or you Ale y; or (c) you violate' any term of *b a?oement If you uo in de6mk we ids red you a notice of she dg Wk and Wvc you 15 de to cure the ?Guh If the k is not maad in drat dme,+ne tbeh have the Tight to demand the etttint amogm owed em your sccatmt and be paid •tmmedistely. if ern begin tONC11011 Wocmiti , you agree to pay all oWliW -:eati, court than and alteasols tees in on aaaomit•piirmlreg by law, L 10. LATE FEE: Any payment dd(nquent ire (10) deyi or maers rimmed a fifteen dollar and fifty =9 (SI5.50) late charge which will be added to your accoun? This armwnt can be changed from time to time open to days prior notira•. I IL CREDIT INFORMATION: You autho.in us to Obtain a media report and any other intonation about your aedihvorlbincaa, You further authorise as ta llamiah into.. tion about your account to credit reporting agencies and anyone else who may lawfully receive such information. .+t-I 12, CHANC$ IN TERM& We may make changes Ira the recce Will other teem of this aptextKttt, as peratuad by law, upon preen notice of tltaac chanson cony 4angp in the eatet and OthQ toms may gtP1Y bete ,omen.- pub and to the owdlatdnng balance on your account. You will be notified at least 6fleat (15) days in advance of any such chrism and such notice wit be amt b your eurlanl addrep as'show•o on the teadtdi of your account. ucts and title th not to 13. SECURITY AGREEMENT: This anent is a 9oarity Agreerrem r covering ' we purchased the ptrYnlou father agree that purchasedtoprodactz rJStpus k art?t art all po. " is hereunder, d' w collection she sad mry you fittly paid. all or iasuxed on or in the premises described herein and aiax-nMihe mm,ved therefrom without out written consent or our assignee's written consent and dial shall not make any matsrbl cWusge theme without our consent. you Is. RETURNED PAYMENT: In the event any payrte e; arc returned to the holder of this agreement nor paid by a bank, you will be charged a service fee at the prevailing Tate. currently 520.00. This amount can change from time to (role upon prior nonce. I& PRIVACY ACT PROVISION: You hereby suthotizo,the Department of Deferw ant is various departments and comma nth; to verify your social «tmiry number or other identifier and disclose your home address to the amI and holder of xib agremhent so that the holder or this agreement may contact you m connection cotta you 6whe1 buoinas. All information Amosisbed will be used sohdy in comhation with your finaacisl buainas relsitionehip agreenent Yen hereby authorise com=Wcvj o with aty.pnt at. p[gSat slgplnix,, teplding your indebtedaop with the holds of with holder of a, b mod the terms and conditions of airy loon or charge apanne t exaemed.by yott this agreemem shoWd you fall 1.6. MIBCELLANIZOU& That agreement R got effective until yew application has ban uuptad by us and received in its original Gem st our offices in Indiana. You further understand steel the agreement has been demand to lave boo mode in Indiana. We have the right to raise this agreement to any seeigrae of our showing. if we sac lane or ptutial payments or delay attfotemg any of oru aighs under fhb •?aensen? we anal not lase those tights. You may nod wigs this ! a8ceemert or say ri?ia cadet ebb agrcetneat, aed atY attempt b wdl tx .-cell red void. IF more elan one perwn si4m tbia agreemat, each signs will be 'I 1omtY +nd sersally IbMe to Tie nor aY irnds6nednep lhuenned under tltis sgrpehnppt Yon echsowledge tat t1s Meacham u not our anployae or Aaant bur is as hrhdepeadee coatpany. The agteemem tearstisusm Use entice sgreannht he;nvdm xa patleY and cater he bhrafrg ymn ahd Eater b ere benefit of the prpea and '. their rcspeaiva hsin, PopresYaaivaa, axaaroorL asoninistrstas, anamelpo led ssd&µ AIY Provision of thin apesmmt tvhick•ia prohibited by law ebax be '. suamaaaliy rcfomad m !x in compliance tlherewith and "hail ba ineRectve to the extort m probibiterl wlUnut iovaxdatiag die tumuiging provisiom of Mb agreement. NOTICE TO NORTH DAKOTA RESIDENTS: This Instrument is based oppooa a personal solicitation saie, which Is subject to the previdoas of the North Dakota Century Code. Ibis iostremeat is not negotiable, NOTICE TO TEXAS RESIDENTSf To 20 t Carme I Cooor re. t yg?l¢east at Call 317-&14T931. This ante scab ?a?de r iR e w w wfo by a summer Credit Commissioner. 26E1 N. Lsi>or Blvd.,. dSit, TeYSS .•207. Phone 312-936-T6 Lonhct the commissioner relative to any logo a or compbtilxts. MOTICX ANY HOLDER OF THIS CONSUMERCREDIT CONTRACT IS SUBJECT TO 'ALL CLAIMS AND DEFENSES WHICH THE DRDTOR COULD ASSERT AGAINST THE SELLER OF GOOD5 R `SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF, RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HERE- j (UNDER. Customer Service-Kindly ;direct all inquiries concerning your account to Customer Service telephone number st 1.1100.727.2987. 1127, Carmel Indians 46082 oT all oa I!, I 1 PDF created with pdfFactory trial version www cdffactory.com -- ----------- YOUR BILLING RIGHTS AND ADDITIONAL CR9bIT AGMMENT INFORMATION This notice contains important information about your rights and our responsibilities under the Fair Credit Billing Act. Notify Us In Can Of Itrr'ors or Questions About Your BIN If you think your bill k wrongor if you;nwtli mciWItif ion about a transaction on your bill, write us (on a separat sheet) at el Financial Corporation, Inc., Customer Service, PO Box 1127, Carmel Indiana 46082. Write to us as soon as possible. we e must h from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing will not preserve your rights. In your letter, please provide the following information: • Your name and account number. • The dollar amount of the suspected error. • Describe the error and explaiw.Af you can. why yeabe)ieve there.is tm error. ;If you need more information, describe the ift%y are not sure about. If you have autho&td'us to pay your account automitiealry-'from your savings or, checking account, you can st p the payment on any amount you think is wrong. To sip the payment, your letter must reach us these-business days before the au uric payment is scheduled to occur. Your Rights And Responsibilides After We Receive Your Written Notice We must acknowledge your leper within thirty days, unless .wfliave corrected. the error by them V& thin 4hicty days; correct the error or explain why 3ve believe the bil{ was cot'Mi. After we receive your letter, we cifi?not try to collect any amount you question, or report you as'delinquent. We can continue to bill you for the amount in question, including FINANCE CHARGES; and we can apply any unpaid amount against your credit limil. You d not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your bill that are not m que tion. stakt?tf your t , you wt not ve to pay any FINANCE CHARGES related to any questioned amout. If we didn't make a mistake, you may have to pay FINANCE CHARGES and you will have to make up any missed payments on the questioned amount. In either case, we will send you a statement of the amount you owe and the date that it is due. if you fail to pay the amount that we think you owe, we may report you as delinquent. However, if our explanation does not satisfy?you and you write us within ten days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question a pout your bil I; and we must tell anyone we report you to that the matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the fist S50.00 of the questioned amount, itm if your bill was correct. In the event of a dispute with any manufacturer, vendor, patty to the attached agnxmentor supplies thereunder, Applicant(s) agree they will resolve such dispute with them, under warranty, through their customer service facilities, in writing or otherwise, and that Ca. Financial Corporation is responsible only for matters required by the Truth In Lending Act, implementing Regulations and applicable opr Federal Law concerning billing rights summarized above. Waiver, condonation or compromise of any breach or default shall not affect Carmel Financial Corporation's remedies or rights ui oubsequent default, and Applicant(s) accept responsibility for all taxable and non-taxable costs and attorney fees incurred by -Cam for collection, repossession or suit, and agree that this provision shall be binding on any receiver, court of dianolnl ,r Trustdowider I I U.S.C., andthaturAis Carmel Financial Corporation is notified by Certified Mail, all notices shall li ideemed prop riven if deposited, post-paid to the addresses herein, and this Agreement is severable, and if any part or provision is judicially severed emainder shall not be affected thereby. ;or the Purehaae Agreement, Carmel Fiesaroia}Corporatitm will satisfy Applicant(s) obligation thereundes and authorizes shipment of •roducts andlor services described in the Purchase Ag+"man Tlae parda.hrsew agree that the place of pwformsme, extension redil, adjustments, and principle place of business for Carmel Financial Corporation is in Hamilton County, Indiana. Applicant(s) agree sy all costs, repossession, suit, attorney fees for enforcement, intervention and removal of stay, ttstomer Service-Please direct all inquiries concexnin&youraocount to Carmel Financial Corporation, Inc 6082 or call our Customer Service Department at 1-800-727-2987. PO Box 1127, Carmel Indiana i II II I III ?I PDF created with pdfFactory trial version www 2 dffactory.com 02/21/07 14:42:58 1 Contract: 6329-18-0590 GLADYS E HARTFORD 214 N ENOLA DR ENOLA, PA 17025 4,115.20 Transaction TrTran Tran Tran Date TyCode Reference Amount 15-APR-05 P ACH -82.30 20-APR-05 F 72. 4.1 16-MAY-05 P ACH -82.30 20-MAY-05- F 61.03 15-JUN-05 P ACH -82.30 20-JUN-05 F 60.73 20-JUN-05 M NSF ACH 82.30 20-JUN-05 M BNK NSF 20.00 25-JUN-05 L 15.50 15-JUL-05 P ACH -82.30 20-JUL-05 F 62.13 20-JUL-05 M NSF ACH 82.30 20-JUL-05 M BNK NSF 20.00 25-JUL-05 L 15.50 15-AUG-05 P ACH -277.90 18-AUG-05 M NSF ACH 277.90 18-AUG-05 M BNK NSF 20.00 20-AUG-05 F 63.41 25-AUG-05 L 15.50 20-SEP-05 F 65.25 25-SEP-05 L 15.50 20-OCT-05 F 66.46 25-OCT-05 L 15.50 20-NOV-05 F 67.68 25-NOV-05 L 15.50 30-NOV-05 C M MANCO .00 31-DEC-05 Y 72.41 Placement Amount: 4,622.70 End Of Report Carmel Financlial Corporation * * * Beginning Balance * * *: Collection NSF Net Amount Flag Balance 00 4032.90 100 4105.31 .00 4023.01 00 4084.04 .00 Y 4001.74 00 4062.47 .00 4144.77 00 4164.77 .00 4180.27 .00 Y 4097.97 .00 4160.10 00 4242.40 .00 4262.40 .00 4277.90 .00 Y 4000.00 00 4277.90 .00 4297.90 .00 4361.31 .00 4376.81 .00 4442.06 .00 4457.56 00 4524.02 00 4539.52 .00 4607.20 .00 4622.70 00 4622.70 .00 4622.70 EXHIBIT :?s PDF created with pdfFactory trial version www.adffactoty.com y ? . Maoo Of YcJ??L' h4 Plaintiff i h herein, verify that the statements of fact contained in the foregoing Co plaint are true and correct. I understand that false statements herein are made subjeci to the penalties of 18 Pa. C.S. § 4909, relating to unworn falsification to authorities. 1 L4- c)E-- Date. r Account # ,??? - gyp. cut8 s 71 i ?? :? NOTARY SFA RLB)-UFICE ?r THE PAOTHW 'ARY 2V9 APP -6 PM Z: 30 CiU Pi N' VSYL.1?r` NJA ".5o Po AlTY CLI, aaa.o8 e a a 3ash} Sheriffs Office of Cumberland County R Thomas Kline tr of C u+ilbrrth Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE -)F "•='HERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/13/2009 09:22 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 9, 200E at 2122 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gladys E. jHartford, by making known unto herself personally, defendant at 3780 Spring Road TRLR 3A 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. SHERIFF COST: $34.30 SO ANSWERS, April 13, 2009 R THOMAS KLINE, SHERIFF 2009-2156 CARMEL FINANCIAL (CORP. VS GLADYS E. HARTFORD By-::?- Depytf Sheriff C-) ? O C: % -?, Cn ?/ .{ CARMEL FINANCIAL CORPORATION, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. 09-2156 CIVIL TERM GLADYS E. HARTFORD, CIVIL ACTION -LAW Defendant NOTICE TO PLEAD TO: Carmel Financial Corporation C/o Charles F. Bennett, Esquire 4650 Baum Boulevard Pittsburgh, PA 15213 You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. ark . Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 ID No. 33671 Attorney for Gladys E. Hartford CARMEL FINANCIAL CORPORATION, Plaintiff V. GLADYS E. HARTFORD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09-2156 CIVIL TERM CIVIL ACTION - LAW 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 ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objeccionnes a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como de describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para 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 CONSEGUIER 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 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 CARMEL FINANCIAL CORPORATION, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-2156 CIVIL TERM GLADYS E. HARTFORD, Defendant CIVIL ACTION -LAW ANSWER TO COMPLAINT 1. Admitted. 2. Admitted. 3. Denied. It is denied that Defendant was granted a loan. Plaintiff, working in concert with Valley Water Treatment Co., Inc. arranged for the loan in question as part of a sales contract wherein Defendant bought a water filter system from Valley Water Treatment Co., Inc., working in concert with Plaintiff, Carmel Financial Corporation. 4. Admitted. 5. Denied. It is denied that Defendant breached the obligations in question. It is admitted that Defendant stopped making payments, but that was because Defendant had told Plaintiff, along with the beneficiary of this loan, Valley Water Treatment Co., Inc., that the equipment in question did not function properly, and she told Plaintiff along with Valley Water Treatment Co., Inc. to take it away. They did not come and take it away, nor did they fix the equipment. Therefore, Defendant felt that since the contract had clearly been breached, she did not have to pay the money in question. 6. Admitted. 7. Denied. It is denied the principal amount is $4,622.70. Specific proof thereto is demanded at the time of trial. 8. Denied. It is denied that interest at the rate of 17.90% per annum is reasonable or appropriate. Therefore, it is denied that the amount in question has accrued on the account. 9. Denied. It is denied that Defendant has agreed to pay Plaintiff's attorney's fees, and it is denied that Defendant has agreed to pay liquidated damages. Furthermore, it is denied that Defendant owes Plaintiff any money because Plaintiff, in concert with Valley Water Treatment Co., Inc., violated the contract in question by selling defective equipment to the Defendant that did not properly function and Plaintiff/Valley Water Treatment Co., Inc. failed to repair the equipment and/or take the equipment from Defendant's home when asked to do so by her. Likewise, it is absurd, excessive, and unconscionable that Plaintiff should want 17.90% interest, as well as a 25% penalty on top of the interest. 10. Denied. It is denied that Defendant acted improperly, because it is denied that Defendant owes any money unto the Plaintiff based upon the allegations herein regarding an obvious breach of contract. WHEREFORE, Defendant respectfully requests this Honorable Court grant judgment in her favor. NEW MATTER 11. The information contained in the preceding paragraphs is hereby incorporated by reference thereto. 12. This lawsuit involves a financing contract for purchase of a water filter from Valley Water Treatment Co., Inc., acting on concert and cooperation with Plaintiff, Carmel Financial Corporation. Thus, Defendant believes and respectfully avers that the financing contract in question herein as well as the contract to purchase the water filter are related and mutually dependent. 13. Defendant respectfully avers that the warranty for merchantability of fitness was broken to the extent that the water filter failed to operate properly, because the seller made promises that were not true, and because the seller and/or Plaintiff failed to either fix the water filter or remove it from the premises in question. 14. There is a complete failure of consideration herein because the water filter did not operate properly. In furtherance thereto, the Defendant respectfully avers that this contract has been broken. WHEREFORE, Defendant, Gladys E. Hartford, respectfully requests this Honorable Court dismiss the claim of the Plaintiff. Date: -?L?A-7108' Respectfully Submitted, THE LAW OFFICES OF SILLIKER & REINHOLD Mark T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 I.D. No. 33671 (717) 671-1500 Attorney for Defendant, Gladys E. Hartford AFFIDAVIT hereby certify that the aforegoing is 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. 4909 relating to unsworn falsifications to authorities. Dated: 'q ???? 6py OF TH FE P'-" 2039 MAY i 1 AFI ;?* 2 1 cup E a ;''' p A OF C] � EU`Bt' � GORDON & WEINBERG, P.C. �� PRQrNOPdOTAR�` BY: FREDERIC I . WEINBERG, ESQUIRE 2013SEP -9 PH 2: 0 Identification No. : 41360 CUMBERLANo JOEL M. FLINK, ESQUIRE PEHNS Y COUNTY Identification No. : 41200 LVA CQ Q 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Carmel Financial Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY VS . DOCKET NO. : 2009-02156 Gladys E. Hartford STATEMENT OF INTENTION TO PROCEED TO THE COURT: Plaintiff intends to proceed with the above-captioned matter. GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE � 1 * Attorney for Plaintiff Dated: -2 CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of foregoing pursuant to Pa. R.C. P. 1028©) (1) , via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERIC I . INBERG, ESQUIRE Dated: P018 R IN THE COURT OF COMMON PLEAS OF C trA rv... c , lap.: CUMBERLAND COUNTY,PENNSYLVANIA NO r ] Del • C _ .. 4 C9 L. • RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE,THE JUDGES OF SAID COURT: , counsel for the plaintif i defendant in the above action(1k. ,respectfully represents that: 1. The above-captioned action( :)is( )at issue. 2. The claim of plaintiff in the action is$ q 2_2_ '7 0 The counterclaim of the defendant in the action is /A The following attorneys are interested in the case(s)as counsel or are otherwise disqualified to sit as arbitrators: ri; ( AI\ WHEREFORE,your petitioner prays your Honorable Court to appoint three(3)arbitrators to p d whom the case shall be submitted. / dS)SCI 0t R c 1. es ••,"tted, 3S2.5 o?q a 38 ORDER OF COURT AND NOW, , 200 , in consideration of the foregoing petition, Esq.,and Esq.,and Esq., are appointed arbitrators in the above captioned action(or actions)as prayed for. By the Court, EDGAR B.BAYLEY 2080345 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Carmel Financial Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY vs . DOCKET NO. : 2009-02156 Gladys E. Hartford CERTIFICATION OF SERVICE I, JOEL M. FLINK, ESQUIRE, hereby certify that I, on the date below, served a copy of Petition for Appointment of Arbitrators pursuant to the to Pa. R. C. P. 1028 (c) (1) , via First Class Mail, postage pre-paid, to all other parties or their counsel of record. A JOEL M. FLING, E QUIRE Dated: 9/5/13 p020 • Cdt. IN THE COURT OF COMMON PLEAS OF ►�nr 1 l'lfl ��i CUMBERLAND COUNTY,PENNSYLVANIA \V3 .. p -2.I NO. r•r- r :, t- d` Cam` Ii4f-4-rbl `�Z": C� tJ 5. r.. t`_` • • •—•i , •-• • • Crx RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE,THE JUDGES OF SAID COURT: J` A ' r(11 " - , counsel for the plaintif i defendant in the above action(gtFlliti44),respectfully represents that: 1. The above-captioned action(agatildreft)is(WI)at issue. 2. The claim of plaintiff in the action is$ (i ZZ •"70 The counterclaim of the defendant in the action is / . The following attorneys are interested in the case(s)as counsel or are otherwise disqualified to sit as arbitrators: :50-e/( OIL r.); ,-) 14 Ari .•� -': 5; f i 4,2 WHEREFORE,your petitioner prays your Honorable Court to appoint arbitrators to PP three (3) whom the case shall be submitted. ` g WW.SePat#11 3 8� 5s R c �Ors •'sifted, Pfrdcl(o a 3g ORDER OF COURT AND NOW, (0.4tal t .) y , 20,63 ,in consideration of the foregoing petition, 7(.1-60lp,,.. Esq.,and 71 Z1___ ___ Esq.,and QM cJai/Yt Esq.,are appointed arbitrators in the above ca tioired action(or actions)as prayed for. ""r* "CC By the Court, 4 / 6 I, _I:_...I r-- ` o c/i filo L .`i I;Kec, � R'-- O E AR B.BAYLEY LLB LFJ Y A rd ¢' o ` 4 p c r� F, CL. N �r K �S�q 9.�. ) Dyes ,t7•ed iv 17//3 2080345 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Carmel Financial Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. : 2009-02156 Gladys E. Hartford CERTIFICATION OF SERVICE I, JOEL M. FLINK, ESQUIRE, hereby certify that I, on the date below, served a copy of Petition for Appointment of Arbitrators pursuant to the to Pa. R. C. P. 1028 (c) (1) , via First Class Mail, postage pre-paid, to all other parties or their counsel of record. u JOEL M. FLIN �, . "'WIRE V Dated: 9/5/13 ' p020 CARMEL FINANCIAL CORPORATION : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA. Plaintiff • NO. 09 CIVIL 2156 v. : (09-2156-CV) GLADYS E. HARTFORD • Defendant • TICE OF HEARING You are hereby notified that the above-captioned case has been scheduled to be heard by the duly appointed Board of Arbitration on Friday, December 11, 2013 at 9:00 a.m. in the second floor hearing room of the old Cumberland County Courthouse. By: \ Kathleen K. Shaulis, Esq. Chairman of the Board of Arbitration Date: October 28, 2013 Joel M. Flink. Esquire Mark T. Silliker, Esquire Counsel for Plaintiff Counsel for Defendant Gordon and Weinberg P. C. Silliker and Reinhold 1001 E. Hector Street, Suite 200 5922 Linglestown Road Conshohocken, PA 19428 Harrisburg, PA 17112 Jane Adams, Esquire Tabitha Tanner, Esquire Arbitration Board Member Arbitration Board Member Adams Law Office Tanner Law Office 17 W. South Stret 3507 Market Street, Suite 303 Carlisle, PA 17013 Camp Hill, PA 17011 4,. -rr m .7 Carmel Financial Corporation In the Court of Common Pleas of Cumberland Plaintiff Gladys E. Hartford County, Pennsylvania No. Q9 -02156 Defendant Civil Action—Law. Oath We do solemnly swear(or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonweal h and that we will discharge the du of our office w' fidelity. ' /� Si a ature Signature /gnature Kathleen K. Shaulis Tabetha A. Tanner /ane Adams Name(Chairman) Name Name Shaulis Law Office Tanner Barcavage Law Office of Jane Adams, Esq. Law Firm Law Firm Law Firm P.O. Box 1229 3507 Market St., Suite 303 17 West South Street Address Address Address Carlisle, PA 17013 Camp Hill, PA 17011 Carlisle, PA 17013 City, Zip City, Zip City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) Plaintiff is awarded$4622.70 plus record court costs. .Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: / _ / / - 1, Date of Award: ; _. r a, I 411 (Chairman)• #44/ ,P / i O Notice of Entry of Award Now, the //54 day of >2 e 7 , , 20 1.3 , at 9 4/7 , A .M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ '2U-0-Le GUe./4=_ Prothonotary Deputy a 03 NC I 1 s). 4 ri 1 ?E*1SY I, 4 dor„ e-‘ d AD/ /1 42 €14‘ r , r , GORDON & WEINBERG, P.C. "'��a°�'2l� BY: FREDERIC I . WEINBERG, ESQUIRE �,'�� n �� '� Identification No. : 41360 EPilys �� ��� JOEL M. FLINK, ESQUIRE � ��xSYLVAQ +� Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Carmel Financial Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY VS . DOCKET NO. : 2009-02156 Gladys E. Hartford PRAECIPE TO ENTER JUDGMENT ON ARBITRATION AWARD TO THE PROTHONOTARY: Please enter judgment on the attached arbitration award in favor of the plaintiff, Carmel Financial Corporation, against the defendant, Gladys E. Hartford in the amount of $4, 622 . 70 . FREDERIC W INBERG, ESQUIRE JOEL M. FL N ESQUIRE Attorney r Plaintiff b a �# lgrG��v GORDON & WEINBERG, P. C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Carmel Financial Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY VS . DOCKET NO. : 2009-02156 Gladys E. Hartford VERIFICATION FREDERIC I . WEINBERG, ESQUIRE, hereby states that he is the attorney for the plaintiff in this action and verifies that the statements made in the foregoing pleadings are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa. C. S . Section 4904 relating to unsworn falsification to authorities . FREDERIC I . ERG, ESQUIRE CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of Plaintiff' s Praecipe to Enter Judgment on Arbitration Award, via First Class Mail, postage pre- paid, to all other parties or their counsel of record. Mark T. Silliker Silliker & Reinhold 5922 Linglestown Road Harrisburg, PA 17112 FREDERIC I . 791INBERG, ESQUIRE Dated: P002-14 Carmel Financial Corporation rP In the Court of Common Pleas of Cumberland Plaintiff Gladys.E. Hartford _ county;Pennsylvania No. 09 -02156 Defendant Civil Action-Law. Oath We do solemnly swear(or affirm)that we will support, obey and.defend the Constitution of the United States and the Constitution of this Commonweal and that we will disc ge the du of our office w' fidelity. Sl ature Signature gnature Kathleen K. Shaulis Tabetha A. Tanner are Adams Name(Chairman) Name Name Shaulis Law Office Tanner Barcavage Law Office of Jane Adams, Esq. Law Firm Law Firm Law Firm P.O. Box 1229 3507 Market St.-, Suite 303 17 West South Street Address Address Address Carlisle, PA 17013 Camp Hill,.PA 17011 Carlisle; PA 17013 City, Zip City, Zip City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn(or affirmed);make the following award: (Note: If damages for delay are awarded,they shall be separately stated.) Plaintiff is awarded$4622.70 plus record court costs. .Arbitrator, dissents. (Insert name if applicable.) Date of-Hearing: 1- f� _ � _.`��' ��_ •~ 04. (Chairman) DEC 11 3 2013 Bs/,I l Notice of Entry of Award Now, the // day of_Mgr . ,20. 47 , at 9'x/7 A :M.., the above award was entered upon the docket and notice thereof given by mail to the parties or their.attorneys. Arbitrators' compensation to be paid upon appeal: _ B i y: Prot cat E COPY F nY whereof,l here unto set my hand Deputy and the seal of saki 'a wls,.Pa. � i Department of Defense Manpower Data Results as of:Jan-14.201407:22:59 Center SCRA 3.0 'J Status 1"—on Pursuant to Servicememben Civil Relief Act Last Name: HARTFORD First Name: GLADYS Middle Name: E. Active Duty Status As Of: Jan-14-2014 On Active Duty On Active Duty Status Date Active Dutv Start Dale Active Dutv End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left ithi Active Active DutV Start Date Active Duty End Date status Service Component NA NA No NA This a reflects where the individual left active duty to i i 367 days precedina the Active ate The Member or HislHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Dale Order Notification Start Dale Order Notification End Date Status Service COMDonent NA NA No NA This response reflects whether ft individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. sit JL A%01- Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/OsIPC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: A6NDD31DF05DCAO 2080345 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 _ JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Carmel Financial Corporation COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs . DOCKET NO. : 2009-02156 Gladys E. Hartford 3870 Spring Rad. TRLR 3A Carlisle PA 17013-8785 NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT ON ARBITRATION AWARD HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING IN THE AMOUNT OF $4, 622 .70 . IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL GORDON & WEINBERG, P.C. AT 484-351-0500 GORDON & WEINBERG, P.C. BY: _ FREDERIC WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff Dated: /x;,1,3