HomeMy WebLinkAbout09-3673v
WENDY YOUNG, : IN THE COURT OF CgMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CASE NO. D ? - 3 (o 7 3 c.)v', I
JEFFREY LINN BENDER, : CIVIL ACTION - LAW
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE
CLAIM 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 AN ATTORNEY AND
FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO
SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY
CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED
BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS
IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE PA 17013
(717) 249-3166
NOTICA
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted
debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas
o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara
medidas y pueda entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es
pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para
usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI
NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR
TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE PA 17013
(717) 249-3166
WENDY YOUNG,
Plaintiff
V.
JEFFREY LINN BENDER,
Defendant
AND NOW this day of
the foregoing,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
CASE NO.
CIVIL ACTION - LAW
ORDER
2009, upon consideration of
IT IS HEREBY ORDERED AND DECREED that:
1. Defendant shall pay to Plaintiff all minimum monthly payments due from the date
of execution of the Promissory Note (6/15/06) to the present date in the principal
amount of $154.06 per month, plus interest and reasonable attorneys fees in the
amount of $500.00; and
2. Defendant shall pay to Plaintiff all minimum monthly payments due from the date
of execution of the Promissory Note (12/7/08) to the present date in the principal
amount of $254.66 per month, plus interest and reasonable attorneys fees in the
amount of $500.00; and
3. Such other relief as this Honorable Court deems just.
BY THE COURT:
J.
WENDY YOUNG, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :CASE NO. Q 3 6 7 g C?
JEFFREY LINN BENDER, : CIVIL ACTION - LAW
Defendant
COMPLAINT
AND NOW comes Plaintiff, Wendy Young, by and through her counsel, Mark A.
Mateya, Esquire, and in support avers the following:
1. Plaintiff is Wendy Young, an adult individual presently residing at 30 Bellaire
Park Road, Carlisle, Cumberland County, Pennsylvania 17013.
2. All legal papers may be served upon Plaintiff through her attorney Mark A.
Mateya, Esquire, P.O. Box 127, Boiling Springs, Pennsylvania 17007.
3. Defendant is Jeffrey Linn Bender, an adult individual presently residing at 66 East
Main Street, Plainfield, Cumberland County, Pennsylvania 17081.
COUNT I - BREACH OF CONTRACT
4. On or about June 15, 2006, the Defendant signed a Promissory Note with Plaintiff
in the principal amount of $20,000.00 with an annual interest rate of 6.94%. A copy of the
Promissory Note is attached hereto as Exhibit "A" and is incorporated herein by reference.
5. Defendant has failed to make the minimum monthly payments on the Promissory
Note referenced in Paragraph 4 above in the amount of $154.06.
6. Defendant is in default of the Promissory Note referenced in Paragraph 4 above in
the amount of $20,000.00.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court issue an Order:
That Defendant pay all of the minimum monthly payments due from the date of execution
on June 15, 2006, to the present in the amount of $154.06 per month, plus interest and reasonable
attorneys fees of $500.00.
COUNT II - BREACH OF CONTRACT
7. Paragraphs 1 through 6 above are incorporated herein by reference.
8. On or about December 7, 2008, the Defendant signed a Promissory Note with
Plaintiff in the principal amount of $33,000.00 with an annual interest rate of 6.94%. A copy of
the Promissory Note is attached hereto as Exhibit "B" and is incorporated herein by reference.
9. Defendant has failed to make the minimum monthly payments on the Promissory
Note referenced in Paragraph 8 above in the amount of $254.66.
10. Defendant is in default of the Promissory Note referenced in Paragraph 8 above in
the amount of $33,000.00.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court issue an Order:
That Defendant pay all minimum monthly payments due from the date of execution of
December 7, 2008, up to and including the present date on the Promissory Note in the amount of
$254.66 per month plus interest and reasonable attorneys fees of $500.00.
Respectfully submitted,
Mark A. Mateya, E ire
Attorney ID No. 78931
P.O. Box 127
Boiling Springs PA 17007
/ ?? (717) 241-6500 (717) 241-3099 Fax
Date:
•
•
VERIFICATION
I, Wendy Young, verify that the facts set forth in the foregoing document are true and
correct to the best of my knowledge, information, and belief. I understand that false statements
herein are subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to
authorities.
Wendy oun
DATED: ?5 .q -0
REPAYMENT - I am obligated to repay the principal and the interest that accrues on my ban(s) to the above-named institution
(hereinafter called lender) over a period of 20 years beginning July 15, 2006. 1 agree to make minimum monthly payments as
required at 6.94% interest amortized over 20 years.
PROMISE TO PAY: I promise to pay the lender, or a subsequent holder of the Note, all sums disbursed under the terns of this
Note, plus interest and other fees which may become due as provided in this Note. I understand UM muo* Iona may be
made to me under this Nob. I understand that by accepting any disbursements issued at any time under this Note, I agree to
repay the loans. I understand that each loan is separately enforceable based on a true and exact copy of this Note. I understand
that I may cancel or reduce the amount of any ban by riot accepting or by retuming all or a portion of any disbursement that is
issued. If I do not make any payment on any loan under this Note when it is due, 1 promise to pay all reasonable collection costs,
including attorney fees, court costs, and other fees. 1 will not sign this Note before reading the entire Note, even if 1 am told that I
am not required to read k. I am entitled to an exact copy of this Note. My signature certillees 1 have read, understand, and agree
to the terns and conditions of this Note.
I UNDERSTAND THAT I MAY RECEIVE ONE OR MORE LOANS UNDER THIS MASTER PROMISSORY NOTE AND THAT I
MUST REPAY SUCH LOANS.
TERMS AND CONDITIONS:
Terms and Cond'titNms (ront)
DISCLOSURE OF LOAN TERMS - I understand that under
tlis Nad, the prindpai amourt that I owe. and am required to
repay, will be the sum of all disbursements issued unless 1
reduce or cancel any disbursements. The lender will
determine whether to make any loan under this Note after
my loan eligibility is determined.
PREPAYMENT - I may prepay all or any part of my unpaid
loan balance, plus any accrued interest, at any time without
penalty.
??f? - ?- - r
Signature:
?r
Date: Co - `v 4'
WMMUH MONTNLY PAYMENT - If required by the lender,
I will make a minimum monody payment in the amount of
$154.06
REPAYMENT - I am obligated to repay the principal and the interest that aoaues on my loan(s) to the above-named institution
(hereinafter called lender) over a period of 20 years beginning January 1, 2009. 1 agree to make minimum monthly payments as
required at 6.94% interest amortized over 20 years.
PROMISE TO PAY: I promise to pay the lender, or a subsequent holder of the Note, all sums disbursed under the terms of this
Note, plus interest and other fees which may become due as provided in this Note. I understand VW muldpie Iwo may be
made to me under this Note. I understand that by accepting any disbursements issued at any time under this Note, I agree to
repay the loans. I understand that each loan is separately enforceable based on a true and exact copy of tlra Note. I understand
that I may cancel or reduce the amount of any loan by riot accepting or by returning an or a portion of any disbursement that is
issued. If I do not make any payment on any loan under this Note when it is due, I promise to pay all reasonable collection costs,
including attorney fees, court costs, and other fees. I will not sign this Note before reading the entire Note, even ff I am told that I
am not required to read it. I am entitled to an exact copy of this Note. My signature certifies I have read, understand, and agree
to the terms and conditions of this Note.
I UNDERSTAND THAT I MAY RECEIVE ONE OR MORE LOANS UNDER THIS MASTER PROMISSORY NOTE AND THAT I
MUST REPAY SUCH LOANS.
TERMS AND CONDITIONS:
Terms and Conditions (cont.)
DISCLOSURE OF LOAN TERMS - I understand that under
this Note, the principal amount that I owe, and am required to
repay, will be the sum of all disbursements issued unless I
reduce or cancel any disbursements. The lender will
determine whether to make any loan under this Note after
my loan eligibility is determined.
PREPAYMENT - I may prepay all or any part of my unpaid
loan balance, plus any accrued interest, at any time without
penalty.
Signature: G /)&-,?
I/
Date: 12 - 7- 09
MINIMUM MONTHLY PAYMENT - It required by the lender,
I will make a minimum monthly payment in the amount of
$254.66
I understand that the lender has the right to call the loan
due and payable in full in the event I tail to maintain
repayment in a timely fashion at any time during the
terms of this Note.
n14
FIL; r?
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WENDY YOUNG,
Plaintiff
V.
JEFFREY LINN BENDER,
Defendant
: IN THE COURT OF COMMON EAS
: CUMBERLAND COUNTY, PEN SYLVANIA
CASE NO. 09-3673 Civil Term
CIVIL ACTION - LAW
AFFIDAVIT OF SERVICE
AND NOW, this 9th day of June. 2009, comes Mark A. Mateya, Esq
Plaintiff, who, being duly sworn according to law, deposes and says that:
1.
4, 2009.
A Complaint for Breach of Contract was filed to the above term and m
2. On June 4, 2009, a certified copy of the Complaint for Breach of Cot
to the Defendant via certified mail, restricted delivery, return receipt requested pursua
1920.4. See the Receipt attached hereto as Exhibit "A" and incorporated herein by
3. On June 4, 2009, a certified copy of the Complaint for Breach of Contract
Defendant via first class mail, postage prepaid. A copy of the Certificate of Mai:
hereto as Exhibit "B" and is incorporated herein by reference.
, Attorney for
tuber on June
'act was sent
to Pa. R.C.P.
;sent tothe
is attached
4. On or about June 9, 2009, undersigned counsel for Plaintiff received the return receipt
card signed by the Defendant on June 5, 2009. Said receipt is attached hereto as Exhibit "A" and is
incorporated herein by reference.
Respectfully submitted,
k1k,
Mark A. Mateya, lUsquire
Attorney I.D. No. 78931
P.O. Box 127
Boiling Springs, PA 17007
(717) 241-6500
(717) 241-3099 Fax
Attorney for Plaintiff
Postal
CERTIFIED MAIL REC EIPT
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1. Artide Addressed to:
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A. Signature X ?? r- Agent
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2. MArticle ans Number
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PS Form 3811, February 2ow Domestic Return Receipt 1 5-02-M.t tBd'o ,
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
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PS Form 3817, Mar. 1989
OF THE
2009 JUN i i AM 9: 0 f
PtNIV ;YL.L `-'+,'`NiA
WENDY YOUNG,
Plaintiff
v.
JEFFREY LINN BENDER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CASE N0.09-3673 Civil Term
CIVIL ACTION -LAW
PRAECIPE FOR DEFAULT JUDGMENT
AND NOW comes Plaintiff, Wendy Young, by and through her counsel, Mark A.
Mateya, Esquire, and in support avers the following:
1. This matter was commenced by Plaintiff by way of filing a Complaint for Breach
of Contract to the above term and number on June 4, 2009.
2. Service of the Complaint for Breach of Contract was effectuated upon the
Defendant on June 5, 2009. See Affidavit of Service filed with this Honorable Court on June 11,
2009.
3. Defendant has failed to file a response to the Complaint and has had no legal
representative enter their appearance on his behalf in this matter.
4. On or about June 26, 2009, Plaintiff served Defendant with a ten (10) day Notice
of intention to request entry of a default Judgment by way of U.S. First Class Mail as well as
U.S. Certified Mail.
5. It is hereby certified that a written notice of intention to file this Praecipe was
mailed to the Defendant after the default occurred and at least ten (10) days prior to the date of
the filing of this Praecipe. See Exhibits "A" and "B" attached hereto.
6. Defendant is in default and in breach of contract with the Plaintiff in the principal
amount of $53,000.00 plus legal fees in an amount of $1,500.00 for a total amount due of
$54,500.00.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
in accordance with the following:
Granting Plaintiff's Motion for Default Judgment against the Defendant;
2. Enter Judgment in favor of Plaintiff and against the Defendant above-named for
failure to file within the required time an Answer to the Complaint in the above-
captioned case;
3. Award Plaintiff s request for damages in the amount of $54,500.00; and
4. Such other relief that this Honorable Court deems just.
Respectfully submitted,
U`~
Mark A. Mateya, Es wire
Attorney ID No. 78931
P.O. Box 127
Boiling Springs PA 17007
(717) 241-6500
(717) 241-3099 Fax
Counsel for Plaintiff
Date:
WENDY YOUNG,
Plaintiff
v.
JEFFREY LINN BENDER,
Defendant
TO: JEFFREY LINN BENDER
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CASE N0.09-3673 Civil 'Term
CIVIL ACTION -LAW
DATE OF NOTICE:_ JUNE 26, 2009
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINS YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST
YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE PA 17013
(717) 249-3166
EXHIBIT
A
AVISO IMPORTANTE
A: JEFFREY LINN BENDER
(Defendido)
FECHA DEL AVISO: JUNE 26, 2009
LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR
COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y
SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS
QUE SE HAN PRESENTADO CONTRA LISTED A MENOS QUE LISTED ACTUE
DENTRO DDE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE
TOMAR UNA DECISION EN CONTRA SOYA SIN TENER DERECHOS A UNA VISTA
Y LISTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A
CERCA DE COMOCONSEGUIR UN ABOGADO.
SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES
POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OF REZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO
A PERSONAS QUE CULIFICAN.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE PA 17013
(717) 249-3166
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
1~T~V ~ ~. A tc~ ~i ~ m
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One piece of ordinary mail addressed to:
~~~~~eEy ~-. "~~ND~~
~n ~ ~ AST-" ~ A ! ~J ~`"
~~. A rev ~~~~.~ PA 17 ~8I
PS Form 3817, Mar. 1989
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^ Complete iterrts 1.2, and 3. Also complete
kem 4 ff Restricted Delivery is desired.
^ Print your name end address on the reverse
so that we can return the card to you.
^ Attach this card to the bade of the mailpieee,
or on the front H space permits.
1. Ardele Addressed to:
A. Signature
X ~ °
^ Addressee
B. d (Printed Name) C. Date of Delivery
D. la deliveiy address dMerertt from Item 1? ^ Yes
H YES, enter delNery address below: ^ No
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2' ~e~'n'~°` 7008 281
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PS Form 3811, February 2004 Domestic Return Receipt ~o25ss.o2.M-ts4p
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^" "niC^C~OCC^C^^^^"""n"' ukC~I#~C7'""' BEAxCAIF~,-'lC#^CG£Ai-~C'~<G
Y'Y YYY~YYYYYYYYYYYYYYY ~Y~~Y~'Y~~YYYp
r' ~ i ~.i'i' d ~,'`
~~~// ~
WENDY YOUNG,
Plaintiff
v.
JEFFREY LINN BENDER,
Defendant
[N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CASE N0.09-3673 Civil Term
CIVIL ACTION -LAW
TO: JEFFREY LINN BENDER, DEFENDANT
You are hereby notified that on G. ~ 7 , 2009, the following Judgment
has been entered against you in the abov -capti ned case.
Judgment entered in the amount of $
Date:~..,~~ /7 ~~
SL.S?D.DD
Prothonotary /~G
I hereby certify that the name and address of the proper person(s) to receive this notice is:
Jeffrey Linn Bender
66 East Main Street
Plainfield, PA 17081
A JEFFREY LINN BENDER, Defendido
Por este medio se le esta notificando que el , 2009, la
siguiente (Fallo) ha lido anotado en contra suya en el caso mencionado en el epigrafe.
FECHA:
Protonotario
Certificao que la siguiente direccion es la del defendido segun indicada en el certificado
de residencia:
Jeffrey Linn Bender
66 East Main Street
Plainfield, PA 17081
Abogado del Demandante
1
R. THOMAS KLINE
Sheriff
EDWARD L. SCHORPP
Solicitor
To Whom It May Concern:
October 13, 2009
Wendy Young
RONNY R. ANDERSON
Chief Deputy
JODY S. SMITH
Real Estate Sergeant
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vs
Jeffrey Linn Bender :~
Writ No. 2009-3673 `J
Property Claim Determination
Reference is made to Property Claim dated October 2, entered by Lori Ann
Doverspike, Writ of Execution No. 2009-3673 Civil Term, Wendy Young vs Jeffrey Linn
Bender.
R. Thomas Kline, Sheriff, has determined that the claimant, Lori Ann Doverspike,
in the above mentioned property claim, is the owner of the property sett forth in the claim.
cc
Mark A. Mateya, Atty for Plaintiff
Jeffrey Linn Bender, Defendant
Lori Ann Doverspike, Claimant
ou~ti~ of ~CuntbPr~~
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OFFICE OF THE SHERIFF
One Courthouse Square, Room 303 y
Carlisle, Pennsylvania 17013
So Answers:
_f~' F ~.~~~ .
R. 1 fiomas Kline, Sheriff
BY ~ G~:
NOTICE OF PROPERTY CLAIM
Wendy Young In the Court of Common Pleas
Cumberland County, Pennsylvania
VS
Jeffrey Linn Bender No. 2009-3673 Civil Terrn
Writ of Execution
TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST:
You are hereby notified that a property claim, a copy of which is
attached hereto has been filed by Lori Ann Doverspike claiming property
listed therein. Unless an appraisal of the property is requested within (10) days
from the date of this notice, the Sheriff without making an appraisal
will accept the value of the property set forth in the claim.
Date 10-02-09
Cc
Mark A. Mateya, Atty for Pltff
Jeffrey Linn Bender, Defendant
Lori Ann Doverspike, Claimant
r 'f
Sheriff of Cumberland County
B y l~~i~",
-PROPERTY CLAIM
C ~~ ~~ ~l ~~ -~~
S
TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA
In the Court of Common Pleas of
Cumberland County, Pennsylvani~aa~
Writ No.~l_ ~~~ ' ~ -~~ _.,)
The property listed below and levied upon in this case is not the property of the defendant, but is the property of the
undersigned. A list of the claimed property and the values thereof are:
LIST OF PROPERTY
VALUE
.~ ~,c.
l-,. .~ ~ ~~,{
`~~~~
'ail\C=,~;~• `~ .yC--~ ~CJC~"`.
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Dat~ ~ 2 , ~ U ' Claimant.
State of Pennsylvania:
County of Cumberland
above list in the property claim are correct and true.
Sworn and subscribed to before me
This day of
\~ X~Y Lr S~ti~
being duly sworn according to law, deposes and says that the
Claimant
Notary Public j „/ ~~, ic?~ ~ -.,~~i~~ ~ ,~-~~~
THE CLAIlVIANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS:
of
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