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HomeMy WebLinkAbout09-57261w ° First United Bank and Trust Civil Action - Law Plaintiff v No. Dq_ 5'1oZ(p ?v;l lean Jeffrey S. Grove Judge 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 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 claims 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. 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. Pennsylvania Bar Association Legal Reference Service Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 First United Bank and Trust Plaintiff v Jeffrey S. Grove Defendant Civil Action - Law No. O %'- 7.ZC? (?cc?l 7fir - Judge COMPLAINT NOW comes the Plaintiff, by its attorneys, Sharpe & Sharpe, LLP, and for its cause of action against the Defendant says: 1. Plaintiff is First United Bank and Trust, a duly organized Maryland Corporation having an office at 19 South Second Street, Oakland, MD 21550. 2. Defendant Jeffrey S. Grove, a sui juris adult, resides at 342 Airport Road, Shippensburg, Cumberland County, Pennsylvania 17257. 3. On or about June 28, 2004, Defendant executed a "Retail Installment Contract and Security Agreement" (the "Contract"), a true copy of which is attached hereto as Plaintiffs Exhibit 1, and made a part hereof by reference thereto. 4. Under and pursuant to the Contract, Plaintiff loaned the Defendant the sum of $25,681.88, which Defendant agreed to pay back with interest at the rate of 6.49% per annum (the "Loan"). 5. Under and pursuant to the contract, Plaintiff received a security interest in a 2002 Chevrolet Silverado (the "Automobile") as security for the repayment of the Loan. 6. On or about December 20, 2008, Defendant defaulted on the Loan by failing to make a required payment on the Loan. 7. On or about February 9, 2009, Plaintiff sold the Automobile at public sale and received the sum of $6,700.00, which sum was credited by the Plaintiff against the amounts due under the Loan. 8. As of February 26, 2009, the Defendant owed the Plaintiff the sum of $950.46, determined as set forth on the attached Exhibit 2 which is made part hereof by reference thereto and interest accrues from that date at a per diem rate of 0.169. 9. Defendant also owes Plaintiff's attorney fee as authorized in the Contract. 10. Plaintiff's reasonable attorney fee is $1,000.00. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1,950.46, inclusive of attorney's fees together with accrued interest to the date of judgment on the principal balance due ($950.46) at the rate of 6.4900% annually, being 0.169 per day, plus costs of suit. SHARPE & SHARPE, LLP Date: 8 ?U 4 By M Shan Att ey for Plaintiff ID 94655 257 Lincoln Way East Chambersburg, PA 17201 (717) 263-8447 No fill- INSTALLMENT CONTRACT AND SECURITY AGREEMENT Seller THOMAS CHEVROLET-OLDS-GEO Buyer JEFFREY S GROVE 8186 BRANDTS CHURCH RD ST. THOMAS PA 17252 Buyer means each Buyer above. Date 28 JUN 2004 PO BOX 4988g RR M e11eerVmeans tT?e Seger above and anyone to whom the Seller transfers this Contract. SALE: Buyer agrees to purchase the motor vehicle (Vehicle) and services described below from Seller. Buyer agrees to purchase the Vehicle from Seller on the terms of this contract and security agreement (Contract). Buyer understands that Seller is selling Buyer the Vehicle in its present condition. Description of Year 2002 VIN 1??9U72E2224S7 other: Motor Vehicle Make CHEV Lic. Purchased Model SILEXT ? New Used PROMISE TO PAY AND PAYMENT TERMS: Buyer promises to pay Seller the principal amount of $ 25681 oo . Buyer agrees to pay finance charges on the unpaid balance at c 490& % per year from today's date until maturity. Finance charges accumulate on a __?I;;r day basis. After maturity or after Buyer breaks any of the terms of this Contract or after a court judgment, Seller will earn interest on the unpaid balance at 6 _ dgfl I- per year. Buyer agrees to make payments and to pay late charges as provided in the TRUTH IN LENDING DISCLOSURES. Buyer also agrees to pay any additional amounts according to this Contract's terms. ? MINIMUM FINANCE CHARGE: Buyer agrees to pay a minimum finance charge of $ N/A if Buyer pays this Contract in full before Seller has earned that much in finance charges. DOWN PAYMENT: Buyer agrees to pay or apply to the Cash Price, by the date of this Contract, any cash, rebate and net trade-in value described in the ITEMIZATION OF AMOUNT FINANCED. ? Buyer agrees to make payments over an extended period of time or at a future date as part of the cash down payment as shown in the payment schedule in the TRUTH IN LENDING DISCLOSURES. TRUTH IN LENDING DISCLOSURES ANNUAL FINANCE AMOUNT TOTAL OF PAYMENTS TOTAL SALE PRICE PERCENTAGE RATE CHARGE FINANCED The amount Buyer will The total cost of Buyer's The cost of Buyer's credit The dollar amount The amount of credit have paid when Buyer purchase on credit, including as a yearly rate. the credit provided to Buyer or has made all scheduled Buyer's down payment of will cost Buyer. on Buyer's behalf. payments. 00.00 6.4900 $ 1 687 - 36 11187 36 Payment Schedule: B uyer's payment schedule is Number of Payments Amount of Payments When Payments Are Due 66 $464.96 12 AUG 2004 Security: Buyer is giving Seller a security interest in the Motor Vehicle purchased. ? Late Charge: If a payment is more than 10 days late, Seller will charge Buyer 2 % PER MONTH ON AMOUNT OE PAYMENT IN ARREARS Prepayment: If Buyer pays off this Contract early, Buyer ? mayX ? will not have to pay a Minimum Finance Charge. Contract Provisions: Buyer can see the terms of this Contract for any additional information about nonpayment, breaking the terms of this Contract, any required repayment before the scheduled date, and prepayment refunds and penalties. BUYER RESTRICTIONS: If Buyer does not meet this Contract's obligations, Buyer may lose the property that Buyer bought in this sale. SECURITY: Buyer gives Seller a security interest in the Vehicle. Buyer also gives Seller a security interest in all attachments, accessories, and equipment installed or placed in or on the Vehicle. Seller refers to the Vehicle and any items installed or placed in or on the Vehicle as Property. Buyer also gives Seller a security interest in the roceeds of the Property. Seller's interest will not extend to consumer goods unless Buyer acquires ri ys after Seller enters into this Contract or the goods are installed in or affixed to the Vehicle. Buyer EXHIBIT Iterest in proceeds and premium refunds of any insurance and service contracts purchased with this 'fi CREDIT INSURANCE: Credit life insurance a t 1ATION OF AMOUNT FINANCED disability insurance are not required to obtain credit. cludes optional service contracts Single C Joint Premium $ _ TE66 Name of Insurance CompanA-ME RICAN H RITA GF I I Buyer wants the credit insurance coverages indicated above Buyer d/o/b Buyer d/o/b PROPERTY INSURANCE: Buyer must insure the Property securing this Contract. Buyer may provide the insurance through existing policies. Buyer may also provide the insurance by purchasing it through any insurance company allowed by law to do business in Pennsylvania or in the state in which the Vehicle is registered and titled. Thide?tible amount for the insurance may not exceed $ _ . If BuTAets insurance from or through Seller, ?t?er will pay $ for // of coverage. The property insurance premium is calculated as follos: e-Theft and Combined Additional Coverage $ M Deductible, Collision Coverage $ NIA Deductible, Comprehensive Cov. $ - ? $_ Deductible $ The property insurance must protect against loss and physical damage. Buyer must name Seller as beneficiary on the insurance policy. Seller may require additional security before Seller allows Buyer to use insurance proceeds to repair or replace the Property. Buyer will pay all amounts that insurance does not cover. If Buyer fails to obtain or keep insurance or to name Seller as beneficiary, Seller may obtain insurance to protect Seller's interest in the Property. Seller will add the cost of insurance to the amount Buyer owes Seller. Any amount Seller pays for insurance is due immediately and will earn interest at the rate charged after maturity. TRANSFER: Seller transfers this Contract to FIRST UNITED BANK & TRUST PO BOX 9, ,OAKLAND, MD 21550-0009 888-MYBANK4 (Transfer ) under the terms of a separate agreement. ? under the t rms of the TRANSFER BY SELLER section. This transfer is made ? with legal liability ? without legal lialli* S C VROLET?LDS-GEO Sell _ f B e ? GAP WAIVER: A GAP Waiver (debt cancellation contract) is not required to obtain credit and will not be provided unless Buyer signs and agrees to pay the extra cost. If Buyer purchases the GAP Waiver from or through EM"Pv8 will pay N/A for of protection. Buyer must see the GAP Waiver contract for details on the protection it provides. Buyer's signature below means Buyer wants the optional GAP Waiver for the stated amount and term. If no amount or term is stated, uyer has declined any such GAP Waiver ff red. X IX 1z (Bi er`(Date) (Ri iv-r) (Date) a Cash Price $ 2S9Q4 28 _ Manufacturer's Rebate $ -NZA Cash Down Payment $ ;on _ nn Extended Down Payment $ N/A a. Total Cash/Rebate Down $ 500.00 Description of Trade-In _ b. Trade-In Allowance $ c. Less: Amount owing $ Paid to: d. Net Trade-In (b. minus c) $ e. Net Cash/Trade-In (a. plus d.) $ SOO.00 Down Payment (e.; disclose $0 if negative) $ SOO.00 Unpaid Balance of Cash Price $25494.35 Paid to Public Officials $ _ 103.50 Insurance Premiums' $ N/A Filing Fee $ 5100 G?A%aiver, Paid to: - - $ N/A OC/NOTARY FEE ? S 55.00 T L R G CARDS $ N/A N 4 TPLINE S RV/REG FEES - $ 2 00 T? TA $ N/A Total Other Charges $ 187.50 Less: Prepaid Finance Charges $ N/A Amount Financed 95681.88 "Seller may retain or receive a portion of this amount. NOTICE TO BUYER DO NOT SIGN THIS CONTRACT IN BLANK. BUYER IS ENTITLED TO AN EXACT COPY OF THE CONTRACT BUYER SIGNS. KEEP IT TO PROTECT BUYER'S LEGAL RIGHTS. BJEeFFREY S GROVE " / d t- ?y Sign u ` Date Signature Date SellerT AS CHEVROLET-OLDS-GEO By BY SIGNING BELOW BUYER AGREES TO THE TERMS ON PAGES 1 AND 2 OF THIS CONTRACT AND ACKNOWLEDGES RECEIVING A COPY OF THIS CONTRACT. JEFFREY S GROVE Buyer:/ Si Date Signature Date RETAIL INSTALLMENT CONTRACT AND SECURITY AGREEMENT TOTAL SALE PRICE: Seller gave Buyer the opportunity to purchase the Vehicle and described services for the Cash Price or the Total Sale Price. The Total Sale Price is the total price of the Vehicle and any services if you buy them over a period of time. Buyer is purchasing the items over a period of time. The Total Sale Price shown in the TRUTH IN LENDING DISCLOSURES assumes that Buyer will make all payments as scheduled. Buyer may actually pay more or less depending on when Buyer makes payments. Seller charges and collects finance charges. These charges are not more than state or federal law allows. If Buyer pays a finance charge or fee that is more than state or federal law allows, Seller will apply the charge or fee first to reduce the principal and refund any excess to Buyer. Buyer understands and agrees that some payments to third parties as a part of this Contract may involve money retained by Seller or paid back to Seller as commissions or other remuneration. LAW GOVERNING: The law of Pennsylvania will govern this transaction. It is also governed by applicable federal law and regulations. In the event of a dispute the exclusive forum, venue, and place of jurisdiction will be in Pennsylvania, unless otherwise required by law. Any provision that appoints Seller as an agent is not subject to the provisions of 20 Pa.C.S.A. Section 5601 et seq. (Chapter 56; Decedents, Estates and Fiduciaries Code). Seller, by exercising any of Seller's rights under this Contract, does so for the sole benefit of Seller. NAME AND LOCATION: Buyer's name and address indicated on page 1 is Buyer's exact legal name and Buyer's principal residence. Buyer will provide Seller with at least 30 days notice prior to changing Buyer's: name or principal residence. PREPAYMENT: Buyer may prepay this Contract in full or in part at any time. Any partial prepayment will not excuse any later scheduled payment until Buyer pays this Contract in full. Buyer may obtain from Seller or the insurance company named in Buyer's policy or certificate of insurance a refund of any prepaid, unearned insurance premiums. BUYER'S RESPONSIBILITIES TOWARDS PROPERTY: Buyer agrees to do the following: A. Buyer will defend Seller's security interest in the Property against anyone who claims to have an interest in the Property. Buyer will do whatever is necessary to keep Seller's claim to the Property ahead of the claim of anyone else. Seller's claim to the Property comes ahead of the claim of any of Buyer's other creditors. Buyer agrees to sign any additional documents and to provide Seller with any additional information Seller may require to protect Seller's security interest in the Property. B. Buyer will keep the Property in Buyer's possession and in good condition. Buyer will only use the Property for its intended and lawful purposes. Unless otherwise agreed in writing, Buyer will keep the Property at Buyer's address listed on this Contract. C. Buyer will not put the Property up for sale without written permission from Seller. Buyer will not transfer any rights in the Property without first getting Seller's written permission. D. Buyer will pay taxes, fees and expenses on the Property when due. E. Buyer will notify Seller of any loss or damage to the Property. Buyer will provide Seller reasonable access to the Property for the purpose of inspection. Seller may lawfully enter and inspect the Property. PDMA,V1hgr'_ TLJC TCDAAC nE: TL.J10 r1nK1T0A!'T B. Seller may require Buyer to make the Property available to Seller at a place Seller designates that is reasonably convenient to Buyer and Seller. C. Seller may immediately take back the Property by lawful means. In taking the Property, Seller may not unlawfully enter onto Buyer's premises or cause a public disturbance. Seller may sell the Property. Seller may apply amounts Seller receives as provided by law to Seller's reasonable expenses and then to Buyer's obligations. D. Except when prohibited by law, Seller may sue Buyer for additional amounts if the proceeds of a sale do not pay all amounts Buyer owes Seller. Seller may take any or all of the actions described above. Seller's decision not to take any of the actions does not mean that Seller has lost the right to take any of the actions in the future. In addition, Seller may require Buyer to pay Seller immediately, the remaining balance of the amount financed, finance charges and all other agreed charges if Buyer does any of the following: A. Buyer fails to pay one or more installment payments under this Contract. B. Buyer fails to pay taxes levied against the Property. C. Buyer fails to furnish proof of payment of taxes levied against the Property. D. Buyer uses the Property for illegal purposes. Seller will mail to Buyer's last known address any required notice of an intended sale or transfer of the Property. Buyer agrees that notice is reasonable if mailed to Buyer's last known address, as reflected in Seller's records. Buyer agrees that notice mailed ten days before the intended sale or transfer (or such other period of time required by law) is reasonable. Buyer agrees that Seller may take personal property left in or on the Property subject to Buyer's right to recover the personal property. INSURANCE: Buyer agrees to buy insurance on the Property against the risks and for the amounts Seller reasonably requires. In addition: A. Buyer will name Seller as loss payee on any such policy. B. Seller may require added security on this Contract if Seller permits any insurance proceeds to be used to repair or replace the Property. C. If the insurance proceeds do not cover the amounts Buyer still owes Seller, Buyer will pay the difference. D. Buyer will keep the insurance until all debts secured by this Contract are paid. If Buyer does not buy, maintain, and arrange to have Seller named as loss payee, as agreed above, Buyer understands and agrees: A. Seller may, but is riot required to, purchase insurance to protect Seller's interest in the Property. B. The insurance Seller buys may be from an agent or company Buyer might not choose. C. The insurance will not cover Buyer's equity in the Property. D. The premium Seller pays may be substantially higher than the premium Buyer might be required to pay for the insurance Buyer has agreed to buy on this Contract. BUYER'S RIGHTS AND DUTIES: If Seller has taken back the Property, Seller may return this Contract to its former status and return the Property to Buyer. Seller will return this Contract if Buyer pays all past due installments, interest Buyer currently owes, plus any other charges or amounts lawfully due to Seller under this Contract. RiIvar anrnnc to nav fnr thn rnctc of a I' WCIlit if Collor C: E?GVertatils to Kee^ the t-roper[y nrsureu, ii Ieyulleu. •E:. The Property is substantially damaged, destroyed or 'sto en. F. Buyer uses the Property in violation of any rule, regulation or government order. C. The Property is taken by any government authorities. H. A money judgment or tax lien is filed against Buyer. 1. Any of Buyer's property is subject to legal proceedings used to pay for a court order for a money judgment. J. Buyer makes any written statement or provides any financial information to Seller that is untrue or inaccurate. K. Buyer permits any interest in the Property to become above or greater than Seller's interest in the Property. L. Any of Buyer's other creditors make the entire debt owed due immediately. M. A court order for a money judgment or a money judgment against Buyer becomes final. N. Buyer fails to keep any promise rnade in connection with this sale. If Buyer breaks any of the terms of this Contract, Buyer agrees to pay court costs Seller spends to collect amounts Buyer owes. In addition, Buyer agrees to pay reasonable attorneys' fees if Seller refers this Contract to an attorney for collection. If there is more than one Buyer and any one of the Buyers breaks any agreement made in this Contract, Seller may exercise Seller's rights against each Buyer or all Buyers. SELLER'S RIGHTS: If Buyer breaks any of the terms of this Contract, Seller may exercise any or all of Seller's rights under law and this Contract: A. Seller may pay taxes, fees, expenses, or charges on the Property or make repairs to the Property if Buyer has not done so. Seller is not required to do so. Seller will add any amount Seller pays to the amount Buyer owes Seller. This amount is due immediately. This amount will earn interest from the date Seller paid it at the rate that applies after maturity. A. Buyer is responsible for paying amounts owed under this Contract even if another Buyer-has signed this Contract. B. Seller may hold any Buyer responsible for paying this Contract, even if Seller chooses to give up Seller's right to hold any other Buyer responsible. C. Seller may give up Seller's interest in the Property and each Buyer is still responsible for paying this Contract. D. If Seller gives up any of Seller's rights, it will not affect Buyer's responsibility to pay this Contract. E. If Seller extends new credit or renews this Contract, it will not affect Buyer's responsibility to pay this Contract. WARRANTY: Warranty information is provided to Buyer separately. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. IF BUYER IS BUYING A USED VEHICLE, THE INFORMATION BUYER SEES ON THE WINDOW FORM FOR THIS VEHICLE IS PART OF THIS CONTRACT. INFORMATION ON THE WINDOW FORM OVERRIDES ANY CONTRARY PROVISIONS IN THE CONTRACT OF SALE. TRANSFER BY SELLER This section of this Contract allows Seller to transfer this Contract to a third party. This section does not apply to Buyer. Seller transfers to the party listed in the TRANSFER section on this Contract (Transferee) all of Seller's rights, title and interest in this Contract. Seller gives Transferee power, either in Transferee's own name or in Seller's name, to take all actions which Seller could have taken under this Contract. Seller assures Transferee of the following. A. This Contract represents a sale by Seller to Buyer. B. The statements contained in this Contract are true and correct. C. Buyer paid the down payment exactly as stated. D. The sale was completed in accordance with all applicable federal and state laws and regulations. E. This Contract is valid and enforceable. F. The names and signatures on this Contract are true and correct. G. This Contract is not subject to any claims or defenses on the part of Buyer. H. Seller delivered a completely filled-in copy of this Contract to Buyer at the time Buyer signed this Contract. 1. Seller delivered the Vehicle to Buyer in good condition and Buyer accepted the Vehicle. If any of these assurances are broken or untrue, Seller will, upon Transferee's request, repurchase this Contract from Transferee. Seller will repurchase this Contract in cash in the amount of the unpaid balance, including interest, plus the expenses of Transferee, including attorneys' fees. Seller will repay Transferee for any loss sustained by it because of a court ordered deduction of the amount Buyer owes Transferee. Seller will repay Transferee for any loss sustained by it as the result of a recovery made against Transferee. Seller gives up its rights to notice of acceptance of this Transfer, non-payment, non-performance, or any other notice from Transferee. Transferee may change the terms of this Contract with Buyer and any other person obligated under this Contract. Transferee may do so without notice to Seller and without affecting the legal responsibilities of Seller under this Transfer. WITH LEGAL LIABILITY: If this Transfer is made "with legal liability" as indicated in the TRANSFER section on this Contract, Transferee takes this Transfer with certain legal rights against Seller. Seller agrees that if Buyer fails to pay or perform according to the terms of this Contract, Seller will, at Transferee's request, repurchase this Contract. Seller will repurchase this Contract for the amount of the unpaid balance, including finance charges, due at that time. WITHOUT LEGAL LIABILITY: If this Transfer is made "without legal liability" as indicated in the TRANSFER section on this Contract, Transferee takes this Transfer without liability to Seller except as provided above. View Profile - 1990197147-1 Note - 67 Month Consumer Indirect - AIG - Bank 088 Jeffrey S Grove 1990197147-1 Note - 67 Month Consumer Indirect - AIG Payoff Summary Total payoff: As of Total daily accrual Payoff Detail Current principal Interest: 01 Accruing Dealer Total payoff Note Information Category: TLC: Participation: Interest type: Accrual basis: Earn/rebate method Collateral description 950.46 02/23/2009 0.1689089 949.95 -54.04 Daily accrual of 0.1214713 54.55 Daily accrual of 0.0474376 Chargeback amount = -7.57 950.46 - Installment No No S - Simple, in arrears 5 - Actual/365 1 - Accruing (simple interest) 2002 Chevrolet Silverado ?. iirfr;;F. rIS Transactions allowed Teller activity: Quote issued: Loan status: l,nterest accrual: interest paid to: EXHIBIT 2 https:/i insight.metavante.org/opstopb 1 /OpstopSer-vlet/LnViewPayoffQuote Page 1 of 1 Change Quote... - All transactions 0.00 No A - Accruing -54.0435532 05/14/2010 02/23/2009 VERIFICATION I verify that the statements made in the pleading are true and correct. I understand that false statements herein are made subject to the penalties of perjury contained in 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: /Z), am Ferry Collections Manager Q PLP; `}E OF THE 2G"f AU; 19 Ni Cam:,:: - , , I il., ?'?,• *78.5o PA ATT` C& &qal P. a LggoB SHERRY BYRNE, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GREGORY BYRNE, NO. 09-5729 CIVIL TERM/ Defendant/Respondent NO. 09-5710 CIVIL TERM ORDER OF COURT AND NOW, this 26th day of August, 2009, there having been a custody complaint filed at 09-5710 upon which the Court this date is holding a petition for emergency relief, and there having been a custody action filed as part of the divorce action at 09-5729, and at that term and number there having been an order entered already setting the case for a conciliation conference, the custody portion of that case and this case at 09-5710 is consolidated. Rachel D. Allen, Certified Legal Intern Anne MacDonald-Fox, Esquire For Plaintiff Susan K. Candiello, Esquire For Defendant Sheriff .tom g/aR?e?/ prs Sheriffs Office of Cumberland County R Thomas Kline Sheriff ??t?r?tr of ?'uin4rrt??tb Ronny R Anderson Chief Deputy Y ?- Jody S Smith - Civil Process Sergeant OFFICE OF' s"ERIFr Edward L Schorpp Solicitor FILED--)rTIvE OF THE P TH1` N'CTARY First United Bank and Trust vs. Jeffrey S. Grove Case Number 2009-5726 SHERIFF'S RETURN OF SERVICE 08/25/2009 06:19 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jeffrey S. Grove, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Jeffrey S. Grove. The Shippensburg Postmaster has advised the defendant has moved and left no forwarding address. An exact address is not available. SHERIFF COST: $46.44 SO ANSWERS, August 25, 2009 R THOMAS KLINE SHERIFF