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HomeMy WebLinkAbout09-5619 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of CUMBERLAND NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. 5l01 (.1 rvl' NOTICE OF APPEAL Filed 911-1109 Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT NAME OF MDJ ADDRESS OF APPELLANT CITY STATE ZIP CODE C/O AMATO & ASSOCIATES, PC 107 N. COMMERCE WAY BETHLEHEM PA 18017 DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant) 8/5/09 BLUESTONE INVESTMENTS INC. V. BRUCE LINGLE A K A BRUCE LINGLE. JR. DOCKET No. SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT CV-174-09 This block will be signed ONLY when this notation is required under Pa. If appellent was (aalmant (see ra. m.c.ru. i. rvv. ruur(ol rn do iurr R.C.P.D. J. No. 10088. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon Name of appellae(s) appellee(s), to file a complaint in this appeal (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To appellee(s) Name of appellee(s) OWNER (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date , 20 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 COURT FILE TO BE FILED WITH PROTHONOTARY ,OF THE 2C0 911UG 12 FIN I C SS H-DAVIT: 1; E(,t eby wear or affirm that I served a r .,...` the Notice of Appeal. Common Pleas No,.,, upon the Magisterial Disl? `, Judge design wA (dale of -, r,de by perso-al service 1l by (certified) (re M: iej ar.- upon the appel,_;c< by personal servtut 0 by t _. > sender's receil ',r U CPI P 71r ORE ME ,Y OF 0 t 20 v re AOPC 12A-0 * COMMONWEALTH OF PENNSYLVANIA r ni IKITV nF• C>QI?ERLAND Mag. Dist. No.: 09-3-01 MDJ Name: Hon. HAROLD E. BENDER Address: 35 N ORANGE ST SHIPPENSBD>tll:G, PA Telephone: (717 ) 532-7676 17257-0361 BLIIESTONE INVESTIEIATS INC. 107 N C0110ERCE NAY C/O AMATO AND ASSOCIATES BETHLZS=, PA 18017 THIS IS TO NOTIFY YOU THAT: Judgment: FOR DEPENDANT ® Judgment was entered for: (Name) (Date of Judgment) 8/05/09 BRUCE LINGLE A/S/A BRUCE LINGLE JR Judgment was entered against: (Namee) BLVSSTONE INVESTlEWS INC. in the amount of $ ? Defendants are jointly and severally liable. Damages will be assessed on Date & Time ? This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ • "" Judgment Costs $ .06 Interest on Judgment $ .05 Attorney Fees $ .00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. / Date , Magisterial District Judge I certify that this is a true and correct copy of the record of the proceedings containing the judgment. J I) 90 --?)5 J Drys-l NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rBLVESTONE INVESTIMTS INC. 107 N COMMERCE NAY C/O AMATO AND ASSOCIATES LBzTmzam, PA 18017 -J VS. DEFENDANT: NAME and ADDRESS rBRUCE LINGLE A/E/A BRUCE LINGLE JR? .320 ROXBURY RD SHIPPENSBURG, PA 17257 L -? Docket No.: CV-0000174-09 Ale&- Date Filed: 6/22/09 MOMM Date My commission expires first Monday of January, 2012 AOPC 315-07 DATE PRINTED: 8/05/09 , Magisterial District Judge 2:15:00 PM SEAL COMMA F PELVANIA Nor .! SI /Ft C. 0r ( „ NotW PLok Cf } 4}i . ',. Lehigh '__.'J MY Cc> > A r? ^cmJ MO AM1916, 2010 Membor, ?enn9ylve too .? ysociatlon cf Notaries ... _j --to ?` rJ COMMONWEALTH OF PEN COURT OF COMMON PLEAS' Judicial District, County Of CUMBERLAND NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT 1 I COMMON PLEAS No. 09-C619 &VO Ter NOTICE OF APPEAL Fi,16d S /-I/og Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT: MAG. DIST. NO. NAME OF MDJ J)I,% 'S'TONL .INVESTMENTS, INC. 09--3-01 RAROLD E. BENDER ADDRESS OF APPELLANT CITY STATE ZIP CODE 1 '? k Al') ,'' ASSOCIEATES, PC 107 N. COMMERCE WAY BETHLEHEM PA 1.8017 DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant) 8j5'i:)' BLt1ESTONE INVESTMENTS. INC. V. BRUCE LINGLE A/K/A BRUCE LINGLE .1R. DOCKET No. `-1 ! 4-09 This block will be signed ONLY when this notation is required under Pa. If appellent was Claimant (see Pa. R.C.P.D. J. No. 1001(6) in action R.C.P.D. J. No. 10086. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon appellee(s)', to file a complaint in this appeal Name of appellee(s) (Common Pleas No. within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent 11 RULE: To appellee(s) Name of appellee(s) OWNER (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. 4 Date 20 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. i AOPC 312-05 COURT FILE 7185 9704 3350 0003 1305 Postage $ Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees Sent To rV 610 Pos m e ? d "?F4 HO Street, or PO Bo No Bruce Lingle a/k/a Bruce Lingle, Jr Crry. State, zrp+4 320 Roxbury Rd 7185 9704 3350 0003 1350 Postage $ O 4M AA EC Certified Fee to Rn Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) to an Total Postage & Fees Sent To Honorable Harold E. Bender street, ,ant. No., District Court 09-3-01 or PO Box No. City, State, zrp+a 35 W. Orange St. FLED-4-t ICE" 0F TI-ti- ZOG9 AUG 17 FM 2: 19 CUMIIE :1J "-'.' L;N 1 Y --?? .?S/' Whoa COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. Plaintiff vs. No. 09-5619 BRUCE LINGLE a/k/a BRUCE LINGLE, JR : CIVIL ACTION Defendant(s) ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Plaintiff, BLUESTONE INVESTMENTS, INC., in the above-captioned matter. AMATO kTlPS, P.C. By: 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 A DEBT COLLECTION LAW FIRM Dated: August 17, 2009 OF THE F ,7., ^{ARY 20,59 AUGO 20 ki i i : 2b CU ftf i $ kt?,i ?;1! COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. Plaintiff vs. : No. 09-5619 BRUCE LINGLE a/k/a BRUCE LINGLE, JR 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 AMAT SOCIATES, 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 4203922 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 BLUESTONE INVESTMENTS, INC. Plaintiff No. 09-5619 vs. BRUCE LINGLE a/k/a BRUCE LINGLE, JR : CIVIL ACTION Defendant(s) COMPLAINT The above Plaintiff brings this action against the above Defendant to recover the sum of $4,414.53, with interest thereon as hereinafter stated, upon the following causes of action: 1. Plaintiff, BLUESTONE INVESTMENTS, INC., is a Pennsylvania corporation with an address of 107 N. Commerce Way, Bethlehem, PA 18017. 2. Defendant, BRUCE LINGLE a/k/a BRUCE LINGLE, JR, is an adult individual located at 320 Roxbury Rd, Shippensburg, PA 17257. 3. Washington Mutual Bank is the successor in interest to Providian Bank. 4. At the request of Defendant, Washington Mutual Bank, or a predecessor in interest, issued to Defendant a Visa credit card, and from time to time thereafter, Defendant made various purchases, in which transactions Defendant made use of said Visa credit card. A true and correct statement of Defendant's account is attached hereto, made a part hereof and marked Exhibit "A." A true and correct copy of final monthly billing statement sent to Defendant by the bank is attached hereto, made part hereof and collectively marked Exhibit "B." 5. For value received, all rights, title and interest of Washington Mutual Bank in this claim were assigned, transferred and set over to Plaintiff. True and correct copies of the bills of sale selling and assigning all rights, title and interest in this claim to Plaintiff are attached hereto, made part hereof and collectively marked Exhibit "C." 6. By virtue of said assignment, Plaintiff acquired legal title to Defendant's aforementioned credit card account and became the legal holder of the claim against Defendant. 7. Defendant has not adhered to the agreed-upon repayment obligations that govern the aforesaid Visa credit card account, by reason of which Defendant is in default thereof. Defendant received, accepted and made various purchases using the credit card described in Exhibit "A," and a total amount which became due as a result thereof, after allowance for all proper credits for payments and/or adjustments, if any, was $3,931.98. 9. Plaintiff is entitled to receive interest on the above amount determined by applying the statutory interest rate of 6.00% per annum to the past due balance. 10. As of August 17, 2009 the total amount of interest due to Plaintiff is $269.80. 11. Plaintiff is entitled to have the 6.00% interest charge continue to accrue, as set forth above, from August 17, 2009 on down to the date of judgment in this matter. 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, Plaintiff demands judgment against Defendant for $4,414.53 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from August 17, 2009, costs of suit and all other relief to which Plaintiff may be entitled. COUNT II 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 credit card services described in the exhibits attached hereto. 15. Defendant received and accepted the benefit of said credit card services provided by Plaintiff. 16. At all times material hereto, Defendant was aware that Plaintiff was providing the aforesaid credit card 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 credit card services and to incur damages. 18. At all times material hereto, Defendant was unjustly enriched by retaining the benefit of receiving said credit card services without paying Plaintiff fair and reasonable compensation. 19. Allowing Defendant to retain the benefit of said credit card 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 credit card services described in the exhibits attached hereto in the amount of $3,931.98. WHEREFORE, Plaintiff demands judgment against Defendant for $3,931.98 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from August 17, 2009, costs of suit and all other relief to which Plaintiff may be entitled. AMATO A OCI TES, P.C. By: Ronald 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 VERIFICATION Michelle Bright, hereby states that she is the Legal Case Manager of Bluestone Investments, Inc., Plaintiff in this action, and verifies that the statements made in the attached Complaint are true and correct to the best of her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Bright CREDITOR NAME: ORIGINAL CREDITOR: ORIGINAL ACCOUNT #: DEBTOR NAME: BLUESTONE ACCOUNT DATE OPENED: DATE LAST PAID: PRINCIPAL: INTEREST: INTEREST RATE: COLLECTION CHARGES: TOTAL: BLUESTONE INVESTMENTS, INC. c/o Amato & Associates, P.C. 107 N. Commerce WAy Suite 100 Bethlehem, PA 18017 STATEMENT OF ACCOUNT Bluestone Investments, Inc. WASHINGTON MUTUAL FINANCE 4185860285204869 BRUCE LINGLE a/k/a BRUCE LINGLE, JR 1090215 2/1/07 11/16/07 $3,931.98 $269.80 6% $.00 $4,414.53 EXHIBIT ---A- ® WaMu' P.O 1b. 660133, mean, TX 76266.0433 ?IndioaN champ. of address on back We need to hear from you. Nowtthe time to mike a payment. Call 300.280.0561 or visit wamucanhelp.com to learn about easy and convenient payment options. Payment Minimum Balance 43 of Aceounl Due Dais Payment Da7fe120118 Number mnsroe ;t,tto.oo Ss9st.se 4185-8602.8520.4869 AMOUNT ENCLOSED fuse blue or black 1nW N ow Mike Ctia,clus Payable 19 Washington Mutual rirlrrlllrrllllilrrlltlrllrrlrillflrrllrlllrllrrlllrrlrllllr,llllrllr WASHINGTON MUTUAL CARD SERVICES P.O. BOX 660487 DALLAS TX 75266-0487 Ilrrrirlrir rrlrlfllrlrllrtllrrtrlrrllrrlrlrlrllrrlrlrrflllrrrl fts:6a BRUCE W LINGLE JR 320 ROXBURY RD SHIPPENSBURG PA 17257-loos rrrlllrr,trrl?irlrirlrrrl,rrllllrrrllr,rlrrlrrrlrlllrr,lrrr 4185860285204861 0111000 0393198 0012500 18 „ 1w92 12" Jae 1 7 Is 1111110619 PAGE 1 of 1 COLR244C !10110 DETACH HERE 0314,692 11324a Impodarit Messages YOUR ACCOUNT IS PAST DUE AND OVER ITS CREDIT LINE. Please pay the minimum payment listed above along with the warlimil amount immediately. You may also call us st I -SW280.9441 or visit us at www.wamucanhelp.comlor ?a mLtPlrt options. Account Summary Statement Closin Dole 0091138 Credits A Payments 11D•? Credit Lire $3,000.00 Cash Advances + $0.00 AvadeDle Credit tot Cash Advances as of 08rt9N08 $0.00 NEW BALANCE 113.891.98 Tranaaetiona Date Description Amount No Activity This Month FOR BILLING ERRORS AND IMPORTANT INFORMATION, SEE REVERSE OF PAGE 1. Balance Category Average Dally Periodic Consaponding Finance Grace IhBy Balance Rate APR Charges Terms Purchase • Current Cycle $1,410.33 .07947: 26199X' $33,59 Term A Cash - Current Cycle $0.00 .0794% 28.49X' $0.00 Term a Balance Tran/Promo Offer - Current Cycle $2,473.67 .07941: 28.99X• $68.92 Term B Ellectlve ANNUAL PERCENTAGE RATE (APR): 28.58% 'These rates may vary. The Oarnependi,re APR to the, re4 at irda,eet you pay whop you carry a balsnoo on Purehas" or sash sdvan»e. The Effective APR reproeenta yawn total fin011106 tlnreee • Indudina treMaabun Nn such as aaah ,Nance and betmrae Wender feet - cep enaed - a pefeamapa, for 24-hour Automated Account Inlarmation, please call 1-868492-WAMU(9268) or visit us at www.womucards.com Your account is Issued by Washington Mutual Bank, Henderson, NV. In case you misplaced your bill, or simply forgot, a payment is due on this account. Log in at www.wamucanhelpecom where you can: • Make payments online • Update your contact information • Get current account details and much more r54Eaeo3 1107) EXHIBIT ]__g_ Change your ranted Intormetion? Pleas specify below (Coe We or block inkj, Addren: Apt: Lily: Slav: zip: Homy Pfau: ?ktk Mont E•m8: IMPORTANT PAYMENT INFORMATION r 202 65 hTt= i TOmmeletmaimepayatten d yaeamre•patae MOD Meths Yarmymala leaches ssbyrhepayatamdas6ainaiW W upq lop Of ryv Statement. PaYmW3 naelwdat W address en is papnem tarupan by 1100 pm. Monthly thotglh Relay psaplapah Mtdayct, wie a weumdto Lour em0uawa IM mrew0l'OkMd. Reaaaob..adirlmnrmli%ltrevtmsending aym poyalelt. Yaopggwttmud bs aefiakr momeyoder rLawnon ? V.9.brst N V.9. GWh s rd arealIrosMwdM the paPttont covpaa4w llw andrIDdr??m emWpa totto edaoes IMiwtrl. Yw amegapaymMnawywrw rmrma, aedaktprnaybodelaYtpbyupb6dge. . Payrwwwuire.dal.antwinolY try roes krsidwsaaionmeYtwAarawJdaye btwA w b¢cou+o manYYrvncMlinYfWllagwnM7aoP.YmM?lreouallnba eperkwdealstwnmYedtoy, Xypu Ys WktO WelNlglan MY:YaIy ONNeAxeatoaao pbmrw, Mrtoammrdtnatyau amatpeyoalot7pM DaYtw'Udlgd the" 0) s alesst a" eaten OR plYlneradue 0710. To dgR uplorE•mall/Wrts that aulomsliWy wantind you a papnradua datm orla maoinatammOsn abaA OnbsoArmasamaYEspeaPayeNMaptim,Olaeta.of emwarmowhnrdamn .lyar nwh.kroeaas.dayae oeadif a.wanoouraye Mau lopry bMytia m7rinumPaymantpm.m.bW dm omupnm dnpyoa oaWnoa6olvaytn PaM17 One. Pleura swYaurAaaNAgrsamanraitbmapannhanOrerMClanO?w PrymemFaa. BILLING AIGNTS SUMMARY IN CASE OF ERRORS OR OUESTIONSAOOUT Y" BILL 0 you think your bill is wong• r A you mad ears int mosen sines a aarsadbnanYdwCe,wraetetamm-tapmdilemaanprapO NaL WASNPICTON MUTUAL CARD E9MCE9 MLUND NKM P.O.00a 9016, 19sWntb14 CA 9454ANIe M10musln00rhOmYrs+rotTtorlmn80doysdly.naaotywahstiml tllNwhbt the sea a Pahtwn gpamd. Wu ma blophms M as nip so sill not pmserwraww". b youronr,pwwualduwriwry nwmim ar. . Your new0 and beds eam.embat: • TAetld{ranoMddveMpeded.acs • Davbdn.armra.darpl in.7 vus-,shy you berweaone rasrror I ywnsatlrromldormauor5 tareaoearortomyoueo.eeueabaA Ywmnah¦"AlpayanywlauMNqqW111011 MS age but you ewawbaagarod mpsyaro pewgdyawa'dbllulrtnel Nphwaan. Wane w"Idi de your WAS iM M mama Sepal you as dekgent of We any teYawro rxeea time anrsua pu gtlealon. SPECIAL ROLE FOR CREDIT CARD PURCNASEd 1 You Mq 0 WodOm will, mestslyat0000 OrrsOMpsaaYWimst 1Yed she treat aid, and you he" bed N gam aloes wwbrlW cis iagOlearlh pmnadirh.voumW.d Iuwbpayle, arddspemwsduo0111haWade of ¦errbns. 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Won CMDMilne ate daily bow" to 6e Wedwa IWNp is awdm,me OsrridrW to to be d ar burbwit e. d. thaw Mheanea'lrawdatd wales and APR& PRs M" Vol. wry, m M wtmdad pedodie iUmw with wdtsryPS N IM Rime Raw Pr ems maded wall an aaawsk W the Iraq a as Ptadded N you Account AgraeaGm to as "em at Cardin Abcoum dituks. lor eyamide llyourpaymods aal.h IePORT1IM PNPORWTOM sentarteallbmNy80C0unl Ilebaledrldlaeslrenant.you maYaeddluft des to Wwocog em AOcotnl silhia 20 doing 110M the dais you etatsmore was magma To Clow your Mutant Disease na Its Gsbmer 9eNom number on your statement. You may OW" u*V ypp Accam to to tan dluyau to M 00030 yausoocum. 01ANN2 - 2 • t OMM BILL OF SALE FOR VALUE RECEIVED, and pursuant to the terms and conditions of the Account Purchase Agreement between CreditMax Recoveries, LLC. ("Seller") and Bluestone Investments, Inc.. ('Purchaser"), Seller does hereby sell, assign, and convey to Purchaser, its sucessors and assigns, all right, title and interest of Seller in and to those certain Accounts described in Exhibit "A" (the "Accounts"). This BILL OF SALE is executed without recourse, warranty or representation of any kind, expressed or implied, including, without limitation, any warranty or representation as to the collectability of the Accounts, except as specifically provided in the Account Purchase Agreement. Executed this 1 day of April, 2009 1W 4- Michael Bernstein President Credit ax Recoveries,LL EXHIBIT Bill of Sale Arrow Financial Services LLC and Arrow Receivables Trust 2000-1, for value received and in accordance with the terms of the Purchase and Sale Agreement by and among Arrow financial Services LLC and Arrow Receivables Trust 2000.1 (collectively, "SELLER,% and CreditMax Recoveries, LLC CTURCHASER") dated as Of August 8, 2008 (the "Agreement'), does hereby sell, assign and transfer to PURCHASER, its successors and assigns, all right, We and interest in and to the Accounts listed in the Account Schedule attached (as may be amended in accordance with the Agreement) as Appendix A to the Agreement, without recourse and without representation or warranty of collectibility, or otherwise, except to the extent stated in the Agreement. Executed on August 8, 2008 ARROW FINANCIAL SERVICES LLC By' y`' Print Name: Don Lupo Title: Vice President ARROW RECEIVABLES TRUST 2000-1 By: Wilmington Trust Company, not in its individual capacity, but as grantor trustee under the Trust Agreement dated as of April 19, 2000, By: _(?G AA aa?;? Print Namef R3 her L. Simpson Title: Sr. Financial Services Officer 23 Washington Mutual Bank, for. value received and in accordance with the terjus o'the porwazd Flow P.urohuse and Sale.Ag.reement by..and between. V?fOhinl t 4 Mutual Bank, and Arrow Financial Services ULC ( ITURC;FtASER"), daie:d as of February 29, 2008 (the "Agreernenf ), does hereby sell, osign and transfer to pURC}tA 1?R, its successors and assigns, all flight, title fund interest in and to the Accourts listed. in the Accomtt Schedule attached (as may be amended in accordance with (h.- Agreement) as Appendix A to the Agr?ement, without recourse and without represe i.tation or warranty of w1lectibilit r, or otherwise, except to ttte extent stated in the Agreen Lent. Execut,d,`= July 24, 2008 j Cut-ob' Date: 07/18/2008 Ciosing Date: 07/24/2008 WASF rNCVI'ON MUTUAL BANK By: PxIm r lame: Kerry Bmyton Title:." Vice President (Waslai.ngton Mutual Bank will provide an updat led Bill of Sale in connection wid-I each montl dy purchase of Accounts..] Afro%% 30S 7-08 w APPENDIX E3_FMAALIc i fL? ? 4W I .1.. c?r= THE E j rY 2 ]", ALiFG 20 ,14111. 2- J COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. Plaintiff No. 09-5619 Vs. BRUCE LINGLE a/k/a BRUCE LINGLE, JR : CIVIL ACTION Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of Plaintiff's Complaint was served via first class mail, postage prepaid on August 21, 2009: Bruce Lingle Bruce Lingle Jr. 320 Roxbury Rd Shippensburg PA 17257 AMATO AND ASSOCIAT , P.C. By: \ k 1 n Ronald 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 F?LGL"'... i 1't V OF THE' F;,l ':."r -O OTARY 1099 AUG 28 pH 2: 4 6 CUM L d? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW tLUESTONE INVESTMENTS, INC. Plaintiff : No. 09-5619 VS. BRUCE LINGLE a/k/a BRUCE LINGLE, JR : CIVIL ACTION Defendant PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment by default for want of an answer in favor of Plaintiff and against the above-named defendant(s) only and assess damages as follows: Debt $4,414.53 Interest (from August 17, 2009 to September 22, 2009 at 6% per annum) 22.07 Payments Total $4,436.6© 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 COMPLAINT. Pursuant to RCP 237.1, 1 certify that a copy of the annexed written notice(s) of intention to file this praecipe was mailed or delivered to all parties against whom judgment is to be entered and to their attorney of record, if any, after the default occurred, and at least ten days prior to the date of filing of this praecipe. Please note that said notice was mailed to all parties on September 11, 2009. Dated: September 22, 2009 AMAT?: _1f.ASSOCIATES, P.C. By: R6n5ld Amato, Esq., Atty ID #3"2323 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 1090215 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 13LUESTONE INVESTMENTS, INC. Plaintiff No. 09-5619 VS. BRUCE LINGLE a/k/a BRUCE LINGLE, JR CIVIL ACTION Defendant CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: C/o Ronald Amato, Esquire 107 North Commerce Way Bethlehem PA 18017 1 do certify that the precise last known address of the within named defendant is: 320 Roxbury Rd Shippensburg PA 17257 AMATO AND ASSOCIATES, P.C. By: Z5:?Q Ronald 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 BLUESTONE INVESTMENTS, INC. Plaintiff VS. : No. 09-5619 BRUCE LINGLE a/k/a BRUCE LINGLE, JR . 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 Bruce Lingle is over 18 years of age, resides at 320 Roxbury Rd, Shippensburg PA 17257 and is employed; Sworn to and subscribed before me this )cA day of ? 2009 A. NOTAR P NOTARIAL SEAL GZOFFREY a SCHOKNEgC Notary Public HANOVZR TOWNSHIP, NORTHAMPTON CNTY My Commission Expires March 29, 2012 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. Plaintiff No. 09-5619 VS. BRUCE LINGLE a/k/a BRUCE LINGLE, JR Defendant(s) TO: Bruce Lingle a/k/a Bruce Lingle, Jr. 320 Roxbury Rd Shippensburg PA 17257 Date of Notice: September 11, 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 AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 AMATO AND CIATES, P.C. By: Ronald 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 Attorney File# 1090215 -?, OF THE 2Girl, 9 SL' s 28 P 112: U G *14.oo PD AT" coaWA14 e a51 IM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW tLUESTONE INVESTMENTS, INC. Plaintiff : No. 09-5619 VS. BRUCE LINGLE a/k/a BRUCE LINGLE, JR CIVIL ACTION Defendant 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 $4,436.60 ON &Pf. 01$ , 2009. ( ) A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. L:V. ' PR HONG ERLAND COUNTY If you have any questions concerning the above, please contact the undersigned. AMATO(SSOCIATES, P.C. By: Rp akrAmato, 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