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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NA
Plaintiff
VS.
HENRY L TAYLOR TRUCKING, LLC; and
HENRY L TAYLOR
No. lO - 6114 04- v i Mer %
COMPLAINT IN CIVIL ACTION
Defendants
FILED ON BEHALF OF
PNC BANK, NA
COUNSEL OF RECORD OF THIS PARTY:
Michael J. Dougherty
PA I.D #76046
WELTMAN, WEINBERG & REIS CO., L.P.A.
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
215-599-1500
WWR# 08126533
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PNC BANK, NA
Plaintiff(s)
vs.
No.
COMPLAINT IN CIVIL ACTION
HENRY L TAYLOR TRUCKING, LLC; and
HENRY L TAYLOR
Defendant(s)
NOTICE TO DEFEND
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 of 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.
AVISO
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. Hace falta
ascentar una comparencia escrita o en persona o con un
abogado y entregar a 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 puede continuar la demanda en contra
suya sin previo aviso o notificacion. Ademas, la corte
puede decider a favor del demandante y requiere que
usted cumpla con todas las provisioner de esta demanda.
Usted puede perder dinero o sus propiedades u 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 Bar Association
34 South Bedford Street
Carlisle, PA 17013
Tel.: (717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Michael J. Dougherty, Esquire Attorney for Plaintiff(s)
Pa. Identification No. 76046
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
Phone: 215.599.1500
Fax: 215.599.1505
File #08126533
PNC BANK, NA
Court of Common Pleas
Cumberland County
VS.
HENRY L. TAYLOR TRUCKING, LLC; and
HENRY L. TAYLOR
NO.
CIVIL ACTION - COMPLAINT
1. Plaintiff is a national association licensed and authorized to conduct business in
the Commonwealth of Pennsylvania with a place of business located at 4242 Carlisle Pike, Camp
Hill, Pennsylvania 17001.
2. Defendant, Henry L. Taylor, is an adult individual who at all times pertinent
hereto resided at 8209 Foothill Boulevard, #A-286, Sunland, California 91040 and who was all
times pertinent hereto the personal guarantor of the Business Banking Line of Credit referenced
herein.
Defendant, Henry L. Taylor Trucking, LLC is a business organization licensed
and authorized to conduct business in the Commonwealth of Pennsylvania and State of California
and having as one of its places of business 8209 Foothill Boulevard, #A-286, Sunland, California
91040.
4. On or around March 29, 2006 Defendants entered into a Business Banking Line
of Credit Agreement, "the Agreement", with Plaintiff at the specific instance and request of
Defendants. See attached as Exhibit 1, a copy of the Agreement.
5. Pursuant to the Agreement, Defendants were to make monthly payments.
6. Defendants breached the Agreement by failing to make the required monthly
payments.
7. Despite demand for payment, Defendants refuse to pay the amount owed and
have an outstanding balance in the amount of $73,986.62 as of January 28, 2010 with contractual
interest accruing thereon at 8.25%
WHEREFORE, Plaintiff demands judgment be entered in its favor and against
Defendants, jointly and severally, in the amount of $73,986.62 with contractually interest
accruing thereon at the rate of 8.25% from January 28, 2010 and costs.
WELTMAN, WEINBERG AND REIS, CO. L.P.A.
Michael J. D e squire
This law firm is a debt collector attempting to collect this debt for our client and any
information obtained will be used for that purpose.
(Page 2 of 31) tauaWLL 1 V v S V., 00(-) -to f0 c) OCC)
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G PlvCBAN<
BUSINESS BANKING LINE OF CREDIT AGREEMENT
Borrower: HENRY L TAYLOR TRUCKING LLC
1280 NAWAKA RD
BIGLERVILLE PA, 17307
Bank: PNC Bank, National Association
4242 Carlisle Pike
Camp Hill, PA 17001
Maximum Credit: $100,000.00
Annual Fee: $175.00
Initial Index: 7.50%
Margin: 1.00%
Initial Rate: 8.50%
Date of Loan: 03/29/06
Borrower's form of organization:
? Sole Proprietorship
? Corporation
0 Limited Liability
State of Organization: Pennsylvania
Borrower's Tradenames or Tradestyles:
Other Locations of Borrower's Business:
? Waived for first year
? General Partnership ? Limited Partnership
? Subchapter S Corporation ? Non-Profit Corporation
? Business Individual
(Page 3 of
BUSINESS BANKING LINE OF CREDIT AGREEMENT
TERMS AND CONDITIONS
We are pleased to have you as it customer and to provide you with a copy of these terms and conditions (the "Terms and Conditions") governing the
line of credit ("Line") provided to you by us. These Terms and Conditions are an important part of your Business Banking Line of Credit Agreement.
A supply of checks to enable you to begin using your account will be mailed to you shortly. Please read these Terms and Conditions carefully. Your
use or acceptance of any Lire proceeds will be deemed evidence of your agreement to these Terns and Conditions.
DEFINITION4. In this Agreement, the following definitions apply:
"Agreement" means this Business Banking Line of Credit Agreement and any amendment or addendum to this Agreement.
"We," "us," "our' or "Bank" means the Bank identified on the first page of this Agreement or any person or entity to whom the rights of the Bank
have been assigned.
.'You," 'your," "yours" or "Borrower" means the individual(s) or entity(ics) identified on the first page of this Agreement who have applied to the
Bank for the Line, for whom an account has been approval and who are listed above as a Borrower.
"Billing Cycle" means the interval between the dates on which monthly statements are prepared.
"Expiration Date" shall be the date which is one year from the Dale of Loan shown on the first page of this Agreement, or such later date as may
be designated by written notice from us to you.
"Maximum Credit Limit" or "Maximum Credit" means the total dollar amount of credit available to you from time to time, the initial amount of
which is identified on the first page of this Agreement.
'Payment Due Date" means the date which will appear each month as the "Payment Due Date" an the billing statement. The Payment Due Date
will be determined by the Bank at the Bank's discretion.
'Termination" means that you will no longer be able to obtain loans or any extension of credit on this account. Termination affects the account
permanently.
2. GENERAL DESCRIPTION OF THE ACCOUNT. This account is a revolving line account, sometimes called a line of credit. It is intended to be
used only for business purposes. You represent that it will not be used primarily for personal, family, or household purposes. You may obtain loans on
this account in the ways described in the "Account Privileges" section of this Agreement up to the Maximum Credit Limit until this account is
terminated. Interest will be charged on the outstanding principal balance at a rate that may change from time to time. Each new rate will apply to the
outstanding balance on your account and all new borrowings until the rate changes again.
3. AUTHORIZED SIGNERS. In the Agreement, you are to desigrtate the person(s) who are authorized to write chocks or obtain funds from this
account by any other means as we may, from time to time, permit without the signature or endorsement of any other Borrower. Any one of the
authorized signers may act alone. If more than one name is identified as Borrower, each individual Borrower named has authority to write checks or
obtain funds from this account by any other means as we may, from time to time, permit without the signature or endorsement of any other Borrower.
We may honor drafts drawn by an authorized signer even if the drafts are made payable to the signer, to cash, or for deposits to the authorized
signer's personal account. We have no duty to investigate or question the application of Line funds. We may refuse to honor drafts or requests for
funds if we are uncertain as to anyone's continuing authority to act as an authorized signer, or if the signature on a draft does not appear to be that of an
authorized signer.
4. HOW YOU AGREE TO THE TERMS OF THIS ACCOUNT. Applying for the Line, using your account or permitting someone else to use your
account constitutes your agreement with us to be bound by this Agreement.
5. ACCOUNT PRIVILEGES. We have established this account for you with a Maximum Credit Limit in the amount set forth on the first page of
this Agreement which tiny change from time to time and which will appear on your monthly billing statement. You may use this credit to obtain loans
from time to time until the Expiration Date by writing checks given by us to you for that special purpose in amounts of not less than S 1,000.00 or by
using other methods which we may permit. You may not use this account to make payments on this or any other PNC Bank account. You may
continue to obtain loans until this account is terminated or the Expiration Date, whichever is earlier. You authorize us to charge this account for all
checks you write on this account, for loans you make and for interest and any other amounts which you agree in this Agreement to pay. If you lose the
checks which were given to you to obtain loans from this account, or someone has obtained them without your permission, you must tell us
immediately. You acknowledge and agree that in no event will we be under any obligation to extend or renew this account beyond the initial Expiration
Date.
(Page 4 of 31)
We agree topay checks which are dated, drawn and issued on this account by you prior to the earlier of the termination otthis account or the
Expiration Date. We are not obligated to pay checks that cause your balance to execexd tour Maximum Coedit Limit. We arc not obligated to pay any
checks dated, drown or issued by you or received by us afla this account is terminated, of your batatce exceeds your Maximum Credit Limit, or tf your
checks have been reported lost or stolen. You agree that the only checks that you will write to make loans from the account will be those issued by us for
that special purpose.
6. OVERDRAFT PROTECTION. If you elect Overdraft Protection for this account, we will make a deposit to the business checking account with us
designated by you whenever a withdrawal is made from that checking account, either by writing a check from the checking account or in some other way, in
an amount which is more money than the balance in that checking account. The amount which we will deposit will be the amount by which the withdrawal
exceeds the balance in the checkingg account, rounded up to the next whole S1.00; however, the amount which we will deposit will not be less than S50.00.
We will charge the amount of the deposit as a loan from this account. We do not have to make a deposit to the checking account if a deposit will cause'the
balance of this account to exceed the Maximum Credit Limit or would violate this Agreement. Checking account checks which are returned will be subject
to our regular overdraft charges.
7. YOU AGREE:
not to write checks for less than S 1,000.00;
to repay all amounts advanced hereunder together with interest as provided in this Agreement;
not to make loans from this account which will cause the outstanding balance on this account at any time to exceed the Maximum Credit
Limit which we have now approved or may approve at an time in the future;
to immediately ?y the amount of any loans in excess of the Maximum Credit Limit;
to give us such financial statements as we may request from time to time.
to pay us costs of collection, including court costs and reasonable legal fees and expenses allowed bylaw, if we refer your account to an
attorney for collection;
not to give us false information or signatures at any time or let anyone who is not a Borrower use this accotmt;
to pay a Late Charge, as provided in this Agreement, for each month any payment is not made within fifteen (15) days of its Payment Due
Date; and
to honor any and all other promises that you make in this Agreement.
8. SECURITY INTEREST. Money on deposit with us and property held by us secure loans made under this Agreement; collateral securing other
obligations to us may also secure bans under this Agreement.
9. INTEREST. The interest rote on the Line is subject to charge from time to time based on changes in an independent index which will be the highest
Prime Rate published in the "Money Rates" section ol?The Wall Street Journal for the last day of the preceding calendar month which is reported (the
"Index"). The Index is not necessarily the lowest rue we charge on our loans. If the Index becomes unavailable during the term of this account, we may
designate a substitute index after notifying you. We will tell you the currant Index rate upon your request. You understand that we may provide lines of
credit and loans based on other rates as well. The interest rate change will not occur more often than each month. The Index for a Billing Cycle is
determined on the first day of that cycle based on the Index for the last day of the preceding calendar month which is reported. The current Index is set forth
on the first page of this Agreement. The interest rate to be applied to the unpaid principal balance of this account is determined by adding a number of
percentage points (the "Margin") to the Index. This Margin is set forth on the first page of this Agreement, as is the initial interest rate for the account (the
Index rate plus the Margin).
Interest on the principal balance of loans outstanding on this account is computed on a 365/360 simple interest basis; that is, by applying the ratio of
the annual interest rate on the first day of the Billing Cycle over it year of 360 days to obtain a daily periodic rate, multiplied by the average daily principal
balance during the Billing Cycle, multiplied by the actual number of days in the Billing Cycle. Under no circumstances will the interest rate on this account
be more than the maximum rate allowed by applicable law.
10. MONTHLY INTEREST PAYMENTS. You agree to pay the accrued and unpaid interest on this account each month on the Payment Due Date.
Your payments must be sent to us at the address shown above or at such other place as we may designate in writing. Unless otherwise agreed in writing or
required by applicable law, payments will be applied first to any accnied unpaid interest, there to principal, and any remaining amount to any unpaid
collection costs and any late charges.
11. LATE CHARGES. If you fail to pay us the payment due by the payment due date reflected on your monthly statement, we may charge you a Late
Charge of S 100 or s% of the amount past due, whichever is less.
12. AUTOMATIC PAYMENT; DEPOSITORY; INCREASE OF MARGIN. You agree to establish and maintain a business checking account with us
during the term of this Agreement which shall be yourpn nary depository account. You authorize us to deduct your monthly payments on the account from
the checking account automatically. If there are insufficient collected and available funds in the checking account, we will not be required to advance funds
to cover the payment. We reserve the right to terminate the automatic payment service at any time, with or without cause. If you revoke your authorization
for us to automatically deduct your monthly payments on the account from the checking accounl any reason whatsoever or fail to maintain a checking
account with us which may be charged, we may, at our option, upon thirty (30) days notice to you, increase the interest rate Margin set forth on the lust
page of this Agreement by up to 0.25 percentage points (0.25%).
If you fail to establish and maintain your primary depository account with us, we may, at our option, upon thirty (30) days notice to you, increase the
interest rate Margin set forth on [he first page of this Agreement by up to 1.00 percentage points (1.01'/.0 1
Our right to increase the interest rate Margin pursuant to this Section shall be in addition to any other rights or remedies we may have, all of which are
hereby reserved, and shall not constitute a waiver, release or limitation upon our exercise of any such rights or remedies.
(Page 5 of 31)
13. PREPAYMENT. You may pay without penalty all or any portion of the amount owed earlier than it is due. Early psymcnts will not relieve you of
your obligation to continue to make payments ofaccrucd unpaid interest. Rather, they will reduce the principal balance due.
14. MONTHLY STATEMENTS AND CHECKS. We will send you a monthly statement for each billing cycle in which activity is posted to this
account or if there is a debit or credit balance of more than S 1.00 or for any billing cycle is which we impose interest. The statement will show advances
made, the amount due for accrued unpaid interest, payments made and the balance which you owe. All payments must be received by us in U.S. dollars
at the remittance address disclosed an your monthly billing statement. Any subsidiary or affiliate of outs may act as your agent in receiving payments on
this account. Unless you notify of us in writing of errors in the statement within sixty (60) days from the date it is trailed, the statement shall be
considered correct and accepted by you. We need not mail you a statement if we deem this account uncollectable or if delinquency collection
proceedings have been started by us. 1f there is more than one Borrower, each agrees that if the statement is sent to and accepted by any of you, it shall be
considered comet as to and accepted by all of you. We shalt retain all checks drawn on this account.
15. CREDIT REVIEW. By accepting this account, you authorize us to check your credit and employment history and to answer any questions about
our experience with you. You also authorize us to obtain from and exchange information with our affiliates and correspondents. Information from credit
bureaus was obtained with respect to this account. If you ask, we will tell you whether or not a consumer credit report was requested from a credit bureau
and the name and address of the credit bureau(s) that provided the consumer credit report. At our option, we may obtain updated credit bureau reports and
income verifications on you as is reasonably necessary to protect our interests.
16. CUSTOMER INFORMATION. You understand that we share transaction information with PNC Bank affiliates and with any third party that
performs services for us in connection with this account or to whom this account may be transterred. We may also share other information you or a third
party may provide. If you do not wand us to share personal, nonlransaction information with PNC Bank affiliates, please write us at PNC Bank, P. O. Box
96066, Pittsburgh, Pennsylvania 15226. Be sure to include your name, address, account number(s) or Social Security/£IN number (s).
17. DEFAULT. You will be in default if any of the following happens:
a) If you fail to pay any payment when it is due;
b) If you fail to pay us the amount of any advances in excess of the Maximum Credit Limit within ten (10) days after we mail a notice to
you demanding the money.
c) if you use the proceeds of kerns from this account for a purpose not permitted under this Agreement;
d) If you or any guarantor Aid to provide us with an updated financial statement upon our request;
e) If you die, arc put in jail, or ire court with properjunsdiction to do so tends that you are incapacitated;
f) If you make an assignment for the benefit of creditors, if you are or become insolvent, if a receiver is appointed for any par of your
property, or if bankruptcy or receivership proceedings are filed by or against you;
g) If anyone riles a lawsuit or gets a judgment against you, or attaches or levies on any property of yours;
h) If you do not notify us within ten days of any change in your address;
i) If you have made any unvue statements or have provided us with false information or signatures at any time;
j) If you fail to keep any promise or perform any duty in this Agreement or any other loan or agreement with us;
k) If you default under any loan, extension of credit, security agreement, purchase or sales agreement, or any other agreement, in favor of
any other creditor or person that may materially affect any of your property or your ability to repay this account or perform your
obligations under this Agreement;
I) If any creditor tries to take any ofyour property on or in which we have a lien or security interest (this includes a garnishment ofany of
your accounts with us);
m) If you flail to establish and maintain your primary deposit account with us;
n) If a material adverse change occurs in your financial condition, or we believe the prospect of payment or performance of the account is
impaired;
o) If any of the events described in this default section occurs with respect to any guarantorof this account;
p) If any guarantor seeks, claims or otherwise attempts to limit, modify, revoke such guarantor's guaranty of this account or any other loan
with us; or
q) If we, in good faith, deem ourselves insecure.
18. OUR RIGHTS UPON DEFAULT. If a default occurs, we will have no further duty to pay checks or make advances from this account and this
account will be terminated. This will happen without prior notice to you. If we choose, at our sole option, to pay checks from this account or make
advances after default, you agree that we may charge those bans to this account. If any event described in Sections 17(t), (g) or (h) happens, all amounts
which you owe us under this Agreement shall be immediately due end payable without prior notice to you, or right to care, except as required by law. If
any other event specified in Section I T occurs, all amounts watch you owe us under this Agreement shall be due and payable immediately, at our option,
without prior notice to you, or right to cure, except as required by law. The other provisions of this Aggnrexemmrnt will continue to apply to this account. 1f
and/or you are a debtor m an action tiled by or against you under the Bankruptcy Code, unless prohibited by applicable
we get a judgment after default
law the rates applicable to this account will continue to apply to the balances on this account. A default under this Agreement ns a default under every
other note, loan agreement or security agreement that you have with us.
Upon default, if we declare the entiro outstanding principal, unpaid interest and charges on your account immediately due and payable, you must pay
that amount immediately. Upon your default, we may increase the interest Margin up to eve percentage points (5%) over the variable interest rate on this
account, if allowed by law. We may hire or pay someone else to help us collect this account if you fail to pay in accordance with this Agreement. You
agree to pay our collection costs (including, without limitation, the cost of in-house attorneys and staff), whether or not we hire anyone else to help us
collect this account. This includes, subject to any limits under applicable law, our attorneys' fees and legal expenses whether or not there is a lawsuit,
including attorneys' ]bees and legal expenses for bankruptcy proceedings (including efforts to modify or vacate any automatic stay or injunction), apppeals
and any anticipated post judgment collection services, to addition to all other sums provided by law, you will also pay any court costs if not prohibited by
applicable law.
(Page 6 of 31)
19. FEES. Your account is subject to the Annual Fee described on the first page of this Agreement. The Annual Fee will be charged in advance
on the anniversary date of your account and is not refundable.
20. TERMINATION BY YOU. You may terminate this Agreement at any time that you arc not in default by: (i) mailing or delivering a written
notice to us that you are terminating this account; (ii) paying us the outstanding principal balance of the account, the accrued and unpaid interest on
the balance, and all other amounts due in accordance with the terms of this Agreement and (iii) immediately returning all checks and other credit
access devices, if applicable, which are our property and that were provided to you to access your account. You will continue to be liable for any
advances made pursuant to unreturned chocks. Any use of checks after the account is terminated may be considered fraudulent.
21. TERMINATION BY US Upon sixty (60) days prior written notice to you, we may terminate this account, with or without cause, and demand
full payment of the outstanding principal balance of the account, the accrued and unpaid interest on the balance, and all other amounts due in
accordance with the terms of this Agreement. Unless our notice provides otherwise:, we will have no further obligation to make any new loans to
you. Termination under this paragraph will not affect any checks which comply with this Agreement and which were written and issued by you
before the due on the termination notice or any other loans made under this Agreement before the dale onthe termination notice. If we choose, at
our sole option, to pay checks or make advances after we have terminated this account, you agree that we may charge those loans to this account.
After termination, the checks and other credit access devices, if applicable, which arc our property and that were provided to you to access your
account must be returned to us immediately.
22. CONVERSION TO TERM LOAN. We retain the right to convert ell or any part of the outstanding indebtedness under this account into an
amortizing term loan, with or without cause, upon providing sixty (60) days prior written notice to you (the "Conversion Notice"). If we exercise this
nghhl?,. we will compute a new monthly payment with respect to the part of the account so converted (the "Term Loan Portion"), and you will be
advised of wdt new monthly lieymtmt wrUn respect to the Term Loan Portion in the Conversion Notice. Monthly payments on the Term Loan Portion
following the Coaversion Nonce shell be Eased upon en amortization prod spec ifiod in the Conversion Notice (the "Amortization Period")
Subsequent payment on the Term Loan Portion strap be dctertnined monthly and shall be in the amount determined by us to be necessary to fully
dry oft
amortize the then outswndmg principal balanc?e of the account so convoatexl over the then remaining Amortization Period at the effective interest rate
on thdaccourut as of the date the amount of torch payment is calculated by uu. All outstandin4 principal and accrued interest will be due on the last
he Amortaation Period Following the Gonvexsion Notice, the Maximuin Credit Limit of the account shall be reduced to the initial amount of
the Term Loath Portion. You only not telorrow rapaid amounts of then Tama Loan Portion unless otherwise agreed by us. Upon payment in full of the
Term Lose Portion and with our exmsenr. the full amount of the account may be reinstated. All'of the provisions of this Agreement shall apply to the
Term Loan Portion except to the extent inconsistent with this paragraph.
23. OUR LIABILITY. We have no responsibility for failure of any machine, merchant or other party to honor checks or any other means which
we may pam from time to time to be used to obtain a loan from this account. Our liability, if any, for wrongful dishonor ore check written on this
account is limited to your actual damages. Dishonor for any reason as provided under the terms of this Agreement is not wrongful dishonor.
24. POST-DATED. STALE DATED, STOP PAYMENT AND CERTIFICATION OF CHECKS. Procedures and laws applicable to post-dated,
stale dated, and stop payment of chocks in connection with transactions on regular business checking accounts shall apply to checks under this
Agreement. You agree not to issue post-dated checks. You may place a stop payment order on a check by providing us with information on the date,
number, payee, and exact amount,(dollais and cent) of the check at any branch office, or by calling or writing us at the following address: PNC
Bank, Centralized Customer Assistance, 2730 Liberty Avenue, Pittburgh, PA 15222. We will not be liable for paying a check if your request is
incomplete, incorrect in any detail or is not provided to us in a time and manner which affords us a reasonable opportunity to act upon it. We will not
"certify" a check on this account.
23. AMENDMENT OF AGREEMENT. We may amend this Agreement from time to time, in any respect, by giving you written notice where
required by law. Such amendments will apply to outstanding balances and new loans except as otherwise indicated in the written notice. If you do
not agree to be bound by the terms of any woendme nt, you must notify us of your election to terminate the account pursuant to Section 20 of these
Teems and Conditions within thirty (30) days of the date we sent you our notice of the amendment.
26. YOUR RESPONSIBILITIES TO US. If more than one person is identified as Borrower, each and all of you are equally responsible,
individually and together, to us fir payment in lull of this account. If we extend credit to you by posting any advance to your account prior to
receiving written notice of your death or incapacity, such transaction shall be a valid and binding obligation of your estate and upon your heirs and
personal representatives.
27. REMEDIES CUMULATIVE. Ourremedies under this Agreement shall be cumulative and not alternative.
29. DELAY IN ENFORCEMENT. We can delay in enforcing any of our rights under this Agreement without losing them. Any waiver by us of
any provision of this Agreement will not be a waiver of the same or any other provision on any other occasion.
29. ASSIGNMENT. You may not assign or otherwise transfer your rights and_privileges under this Agreement, or delegate your obligations to
r.9my amounts you owe us. Any attempt by you to assign or delegate will be void and of no effect We may assign any and all of our rights under
this Agreement at any time without your consent. A person(s) to whom we assign this Agreement shall be entitled to all of our rights under this
Agreement. None of your rights or obligations shall be effected by such assignment.
30. REPLACEMENT OF PRIOR AGREEMENTS. This Agrccmcnt replaces all earlieragrecmrnts and governs all balances on this account,
including balances carried over onto this account from any prior account. just as if it had been in effect before the first advance from this account.
(Page 7 of 31)
31.. GOVERNING LAW AND CONSTRUCTION: JURISDICTION. This Agreement has been delivered to and accepted by us and will be
deemed to be made in the State where our office indicated on the first page of this Agreement is located. Regardless orthe state of your
residence, you agree that this Agreement will be interpreted, and the rights and liabflides of the parties determined, in accordance with, the laws
of the State where our office indicated on the first page of this Agreement is located, excluding its conflict of laws rules. You irrevocably
content to the exclusive jurisdiction of any state or federal court located for the county or judicial district where our office indicated on the first
page of this Agreement is roosted, and consent that all service of process may be cent by nationally recognized overnight courier service directed
to yoo e< your addre? set forth on the first page of this Agreement and service so made will be deemed to be completed on the business day after
deposit with such courier, provided that nothing contained in this Agreeniant will pitvant us from bringing toy action, enforcing any award or
judgment or esercieing as nghts against yon individually, a say saucily of against enY of your property xnthin ally other county, state or
other foreign or domestic urisdiction. You acknowledge agree that the venue provided in this paragraph is the most convenient forum for
both you and us. You waive any objection to venue and any obJecdon based on a molt convenient forum in any action instituted under this
Agreement.
32. SEVERABILITY. If any provision of this Agreement is held to be invalid or unenforceable, such determination shall not affect the
validity or enforceability of the remaining provisions of this Agreement.
33. GENERAL PROVISIONS. To the fullest extent allowed by law, you and any other person who guarantees or is otherwise liable for this
account waive any applicable statute of limitations, presentment, demand for paymLM protest and notice of dishonor. Upon any change of this
Agreement. and unless otherwise expressly stated in writing, no arty obligated on this account, directly or as a guarantor, shall be released from
liability. We may renew or extend (repeatedly and for any length of time) this account, or release any party or guarantor or collateral; or impair.
fail to realize upon or perfect our security inicrsst in any collateral, and take any other action deemed necessary by us without the consent of, or
notice to, anyone. We may modify this account without the consent of, or notice to, anyone other than the party with whom the modification is
made. Any notice to us which is
(Page 8 of 31)
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N1me and 1tb prbrt)
HENRY(k TAYLOR MEMBER None sM Tak tpkax prop
Oft 3128/2006 DIAN
aaitr, no sfpmn(ffaramly, ro
ft me (M INK 0-9 firm V,
HENRY TAYLOR Name (ft Wk Ohre ww
oft 3/28/2006 Da"
P®B=Z Appkedon-PA-05-13.05 Pap 4
(Page 27 of 31)
MAR-22-2006 16 09 PNC BW GSL. DEPT 215 7a9 8773 P.04
i
k
BOMWERS CERTIFICATE
The undersigned borrower ( the "Borrower") acknowledges and understands that:
(a) The loan to be made by PNC Bank, N.A.(the" Lendeel to the Borrower
will be filed for enrollment by the Lender in PennCap, a program established by the
Pennsylvania Economic Development Financing Authority, a public instrumentality
and body corporate and politic of the Commonwealth of Pennsylvania ("PEDFA" ):
(b) The purpose of PennCap it to assist the Lender in making loans to borrowers that
might otherwise not qualify for loans from the Lender;
(c) As a condition of having the Borrower's loan filed for enrollment in pennCap ,
the borrower' is required to pay a nonrefundable premium charge to an administrative
account establis ed by the Trustee, designated Reserve Fwd-( )
(the "Reserve Fund'J, Which Reserve Fund has been established by PEDFA to help
cover losses that the Lender may sustain on loans enrolled in PenuCap; and
(d) The Borrower's payment of its nonrefundable premium charge will be collected by
the Lender for transmittal to the Reserve Fund, and that other payments or transfers
will be made to the reserve Fund by the Lender and PEDFA
The Borrower hereby represents and warrants that it has no, and has not been promised or
told by anyone that it has any, legal, beneficial or equitable interest in such nonrefundable
premium charges or any other funds credited to the Reserve Fund, and the Borrower
hereby waives any right, claim or interest in and to any and all such funds paid or
credited to the Reserve Fund from time to time.
The Borrower further hereby represents and warrants that:
(1) The Borrower is a corporation partnership, join venture, sold proprietorship
cooperative or other entity, whether profit or nonprofit, which is authorized to
conduct business in the Commonwealth of Pennsylvania, and the proceeds of the
Borrower's loan will be used for an endeavor within the Commonwealth of
Pennsylvania in furtherance of the public purposes of the Pennsylvania Economic
Development Financing Law.
(2) The Proceeds of the Borrower's loan will not be used for the financing of
Ineligible Activities (a written list of which list of has been delivered by the '
Lender to the Borrower):
(Page 28 of 31)
MAR-22-2006 16 10 PM BPK GSL DEPT
215 749 8773 P.05
(3) The Borrower is not an executive officer, direct or principal shareholder of the
Lander. or member of the immediate family of any executive officer, director or
principal shareholder of the Lender, or a related interest of any such executive
officer, director principal shareholder or member of the immediate timily.
(4) No member of the General Assembly, official or employee of the Commonwealth
of Pennsylvania, or member of any such person's family, will have any personal
interest in the benefits or proceeds of the Borrower's loan, or shy interest in any
entity having an Interest in such benefits or proceeds.
(5) The Borrower (i) has not been suspended or debarred by the Commonwealth of
Pennsylvania under its Contractor Responsibility Program . (ii) has not been
convicted of a crime for which a term of imprisonment of one year or more could
have been imposed and. and (iii) is not controlled by a person which has been so
suspended, debarred or convicted.
i
i
Datcd: -?c7 3 0 6
HENRY L TAYLOR TRUCKAs Q LLC
-700
G`.
By: HENRY. TAYLOR
Title: MEMBER
i
i
i
TOTAL P.05
t
iL
lJ?nut?Sc'?'? 0.
AR PNCBANC
March 08, 2007
Mr. Henry Taylor
Henry L Taylor Trucking Lid
120 Nawakwa Rd
Biglerville, PA 173079755
RE: Loan #00004003048110528919
Dear Mr. Taylor:
COPY
?r -01-
We extended a $100,000.00 Line to you pursuant to an Agreement dated April 26, 2005 for a Choice Credit
for Business Line of Credit (the'Agreemenr).
This letter Is a Conversion Notice, which Is given to you pursuant to the Agreement. By this letter, you are
notified that, effective sixty (60) days from the date of this Conversion Notice (the "Conversion Date"), the
outstanding balance of the line (the Tenn Loan Portion") will be converted into an amortizing term loan
which shall be payable to us in nx nthy Installments over an Amortization Period of EighWour (84) months,
with such Installments to be payable on your regularly scheduled payment date beginning with the first full
payment cycle after conversion. You are hereby notified pursuant to paragraph 25 of the Agreement that the
Agreement will be amended, effective as of the Converstion Date, to provide that the Interest rate Margin will
be increased by one hundred basis points (1.00%) to 10.25%. Your new interest rate will be equal to Prime Rate
plus 2.00% percent (2.00%) No further advances under the line of credit shalt be made after the Conversion
Date unless otherwise agreed to by us.
Based on the outstanding balance of the line today, the principal amount of each Installment will be in an
amount of $1,190.48. (This amount is an estimate; the actual principal amount to be paid in each'monthy
Installment will be calculated by dividing the outstanding principal balance of the tine of credit on the Conversion
Date by the number of months In the Amortization Period). Interest shall be payable at the satire time as the
principal payments and shell be calculated in accordance with the Agreement. All outstanding principal and
accrued interest will be due and payable on the last day of the. Amortization Period. To the extent that there are
sufficient collected and available funds In your checking account with us, these monthly payments of principal and
Interest will be automatically deducted from your checking account, if applicable. Ali provisions of the Agreement
shall continue to apply to the Term Loan Portion except to they extent inconsistent with this paragraph.
In delivering this Conversion Notice, we in no way waive any right, power or privilege granted to us by the
Agreement. We hereby expressly reserve all of our rights with respect to enforcing any and all such rights,
powers or privileges at any time in the future.
Very Truly Yours,
PNC BANK, NATIONAL ASSOCIATION
By: -
Ron Newfield
Client Management Services
CC : Henry L Taylor, Guarantor
A member of 71c PNC Financial Service" Group
Eutwick Center 8800 Tn icum Boulevard PhaWdphia Penny ania 19153
na•w.pncbank.com 215-749-6500
VERIFICATION PAGE
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn
falsification to authorities, that he/she is&567 12Mh6M , Plaintiff herein, and that he/she is duly authorized
to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of
his/her knowledge, information and belief.
.20 201U
ate (Signa e)
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Michael J. Dougherty, Esquire
I.D. No. 76046
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
Phone: 215.599.1500
Fax: 215.599.1505
File # 08126533
PNC BANK, NA
vs.
HENRY L TAYLOR TRUCKING, LLC; and
HENRY L TAYLOR
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NO. !b - .51!09 I?IVi??1r1"w
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance for Plaintiff, PNC Bank, N.A., in the above-captioned
matter.
By
Michael J. ougherty, Esquire
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Michael J. Dougherty, Esquire
I.D. No. 76046
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
Phone: 215.599.1500
Fax: 215.599.1505
File # 08126533
rtnTAW
Attorney for Plaintiff(s)
E.. 24 PM 3' 5a
WWSYLVANA
PNC BANK, NA CUMBERLAND COUNTY
COURT OF COMMON PLEAS
S.
HENRY L TAYLOR TRUCKING, LLC; and
HENRY L TAYLOR No.: 2010-05169
CERTIFICATE OF SERVICE
TO THE PROTHONOTARY:
On August 12, 2010 Plaintiff, PNC Bank, N.A., served its Complaint in Civil Action upon the
following party/parties in the above-captioned matter via USPS First Class Mail and Certified
Mail, postage-prepaid. Attached as Exhibit "A" is a copy of the certified return receipt(s) from
the United States Postal Service for 7010 1670 0000 2998 0044; and 7010 1670 0000 2998 0051
dated August 14. 2010.
Henry L. Taylor Trucking, L.L.C.
8209 Foothill Boulevard #A-286
Sunland, CA 91040
Henry L. Taylor
8209 Foothill Boulevard #A-286
Sunland, CA 91040
WELTMAN, WEINBERG & RE1S CO., L.P.A.
By
Michael J. Dougherty, Esquire
Attorney for Plaintiff
SENDER: • SECTION COMPLETE TH[3 SECTION ON DELIVERY
t Complete items 1, 2, and 3. Also complete A St
item 4 if Restricted Delivery Is desired. 0 Agent
® Print your name and address on the reverse Afiz-?l - ? Addressee
so that we can return the card to you. c ived by (Printed Name) C. a ofP ivery
® Attach this card to the back of the mailpiece,
or on the front if space permits. l
D. Is delivery address ditterent fro m item 1?
1. Article Addressed to: If YES, enter delivery address below: 0 No
HENRY L TAYLOR
8209 FOOTHILL BLVD #A-286
SUNLAND, CA 91040
i
3. Service Type
certified Mail 0 Express Mail
0 Registered 0 Return Receipt,for Merchandise
0 Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
2. Article Number
(rransterfrom service labeq 7010-1670 0000 2998 0051
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-lW'
UNITED STATES POSTAL' ffie - as %M411
.r ,, ; Ptje?es`
.? ..?; _Y Y?-i ..?. 4. k .?.n? ?'? ?,5+•?i4 . .? .:P.RFrl«IUDA;h7? I l7x 3nV
• Sender: Please print your name, address, and ZIP+4 in this box
MICHAEL J DOUGHERTY, ESQ
WELTMAN, WEINBERG & REIS CO, LPA
325 CHESTNUT ST, STE 501
PHILADELPHIA, PA 19106
WWR#08126533
?tat???t?ttstt?#f?tasa??ssrs?s?s??at??lli 33i?la7?i 19?11af 3?i??1
® Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery Is desired.
® Print your name and address on the reverse
so that we can return the card to you.
® Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
HENRY L TAYLOR TRUCKING,
8209 FOOTHILL BLVD #A-286
SUNLAND, CA 91040
A. Siaaa
0 Agent
/e . €ived b (Printed Name) C e !ve
Lit 0. Is delivery address different from item 1? ? Yes
If YES, enter delivery address below: 0 No
3. Service Type
XgkCertifledl Mail 0 Express Mail
0 Registered 0 Return Receipt for Merchandise
0 Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
2. Article Number
(transfer from service fabeq 7 010 1670 0000 2998 0 0 4 4 --
Ps Form 3811, February 2004 Domestic Return Receipt 102595-02-M-lW
UNITED STATES POSTi4L-StRf flCfe y` , ?" it as I
°- x?s2a?e & Fees Paid
L
I • Sender: Please print your name, address, and ZIP+4 in this box •
MICHAEL J DOUGHERTY, ESQ
WELTMAN, WEINBERG & REIS CO, LPA
325 CHESTNUT ST, STE 501
PHILADELPHIA, PA 19106
WWR#08126533
hill 1111,11111111i1S111}1f33lliSi}i?ii li l?l?.l11?13l 11 F!! dill
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Michael J. Dougherty, Esquire Attorney for Plaintiff(s)
I.D. No. 76046
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
Phone: 215.599.1500
- --,
Fax: 215.599.1505 ~
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WWR # 08126533 -`W' .'`: `°~'
PNC BANK, NA
CUMBERLAND COUNTYr,~~~. ~~~"'
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Plaintiff COURT OF COMMON PLF~i~' ~
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HENRY L TAYLOR TRUCKING, LLC; and NO. ZO10-05169
HENRY L TAYLOR
Defendants
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment against Defendants, Henry L. Taylor Trucking, L.L.C. and Henry L. Taylor, in the
default of an Answer to Plaintiffs Complaint, in the amount of $78,535.28 computed as follows:
Amount claimed in Complaint/Writ
Amount Paid
Interest from 01/28/2010 to 10/27/2010 at the legal interest rate of 8.25% per annum
Attorney fees
73,986.62
0.00
4,548.66
0.00
TOTAL 78,535.28
a"~
a~~' ~~
~ ~~
I hereby certify that appropriate Notices of Default, attached as Exhibit "A", have been mailed in
accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices.
I certify Plaintiff s address as PNC Bank, N.A., 4242 Carlisle Pike, Camp Hill, PA 17001.
I certify that Defendant, Henry L. Taylor Trucking, L.L.C., last known address is 8209 Foothill
Boulevard, # A-286, Sunland, CA 91040.
I certify that Defendant, Henry L. Taylor, last known address is 8209 Foothill Boulevard, # A-286,
Sunland, CA 91040.
Weltman, Weinberg & Reis Co., LPA
By
Michael J. Dou erty, Es ire
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVII. DIVISION
PNC BANK, NA CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
vs.
HENRY L TAYLOR TRUCKING, LLC; and N0.2010-05169
HENRY L TAYLOR
Defendants
NON-MII,ITARY AFFIDAVIT
The undersigned is the duly authorized agent and/or attorney for Plaintiff PNC Bank, N.A. in the within
matter and states as follows:
Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers'
Civil Relief Act (SCRA), 50 U.S.C. App. § 521.
Affiant further states that based upon investigation it is the affiant's belief Defendant Henry L. Taylor is not
in the military service.
Affiant further states that this belief is supported by the attached certificate(s) from the Defense Manpower
Data Center (DMDC), marked as Exhibit "B", which states that the DMDC does not possess any information
indicating that the below individual(s) is/are in the military service:
Henry L. Taylor
8209 Foothill Boulevard, # A-286
Sunland, CA 91040
Affiant further states that the averments contained herein are true and correct to the best of Affiant's
knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A.
§4904 relating to unsworn falsification to authorities.
Weltman, Weinberg & Reis Co., LP
Michael J. Dougherty, Esquire
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Michael J. Dougherty, Esquire Attorney for Plaintiff(s)
I.D. No. 76046
325 Chestnut Street, Suite 501
Philadelphia, PA 19106
Phone: 215.599.1500
Fax: 215.599.1505
WWR # 08126533
PNC BANK, NA CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
HENRY L TAYLOR TRUCKING, LLC; and NO. 2010-05169
HENRY L TAYLOR
To:
HENRY L TAYLOR TRUCKING, LLC
8209 FOOTHILL BLVD #A-286
SUNLAND, CA 91040
Cc:
Date of Notice: 09/17/2010
IMPORTANT NOTICE AVISO IMPORTANTE
YOU ARE IN DEFAULT BECAUSE YOU HAVE
FAILED TO TAKE ACTION REQUIRED OF YOU IN
THIS CASE. UNLESS YOU ACT WITHIN TEN
DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
USTED ESTA EN REBELDIA PORQUE HO
FALLADO EN TOMAR LA ACION EXIDIDA DE SU
PARTE EN ESTE CASO. A MENOS DE LA FECHA
DE USTED ACTUE DENTRO DE DIEZ DIAS DE LA
FECHA DE ESTE AVISO, SE PUEDE REGISTRAR
UNA SENTENCIA CONTRA USTED SIN EL
BENEFICIO DE UNA AUDENCIA Y PUEDE
PERDER SU PROPIEDAD O OTROS DERECHOS
IMPORTANTES. USTED DEBE LLEVAR ESTA
AVISO A UN ABOGADO ENSEGUIDA. SI USTED
NO TIENE UN ABOGADO Y NO PUEDE PAGAR
POR LOS SERVICIOS DE UN ABOGADO, DEBE
COMMUNICARSE CON LA SIGUIENTE OFICINA
PARR AVERIGUAR DONDE PUEDE OBTENER
AYUDA LEGAL:
CUMBERLAND COUNTY BAR ASSOCIATION
34 S BEDFORD ST
CARLISLE, PA 17013
TEL: (717) 249-31,66
Michael J' Dougherty, Esquire
Attorney for Plaintiff
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Michael J. Dougherty, Esquire
I.D. No. 76046
325 Chestnut Street, Suite SOI
Philadelphia, PA 19106
Phone: 215.599.1500
Fax: 215.599.1505 '
WWR # 08126533
PNC BANK, NA
Attorney for Plaintiff(s)
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
vs.
HENRY L TAYLOR TRUCKING, LLC; and
HENRY L TAYLOR
NO. 2010-05169
To:
HENRY L TAYLOR
$209 FOOTHILL BLVD #A-286
SUNLAND, CA 91040
Cc:
Date of Notice: 09/17/2010
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE
FAILED TO TAKE ACTION REQUIRED OF YOU IN
THIS CASE. UNLESS YOU ACT WITHIN TEN
DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
AVISO IMPORTANTE
LISTED ESTA EN REBELDIA PORQUE HO
FALLADO EN TOMAR LA ACION EXIDIDA DE SU
PARTE EN ESTE CASO. A MENOS DE LA FECHA
DE LISTED ACTUE DENTRO DE DIEZ DIAS DE LA
FECHA DE ESTE AVISO, SE PUEDE REGISTRAR
UNA SENTENCIA CONTRA LISTED SIN EL
BENEFICIO DE UNA AUDENCIA Y PUEDE
PERDER SU PROPIEDAD O OTROS DERECHOS
IMPORTANTES. USTED DEBE LLEVAR ESTA
AVISO A UN ABOGADO ENSEGUIDA. SI USTED
NO TIENE UN ABOGADO Y NO PUEDE PAGAR
POR LOS SERVICIOS DE UN ABOGADO, DEBE
COMMUNICARSE CON LA SIGUIENTE OFICINA
PARR AVERIGUAR DONDE PUEDE OBTENER
AYUDA LEGAL:
CUMBERLAND COUNTY BAR ASSOCIATION
34 S BEDFORD 5T
CARLISLE, PA ] 7013
TEL: (717) 249-3166
Michael J. Dougherty, Esquire
Attorney for Plaintiff
'Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Oct-27-2010 10:01:26
*~ Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
TAYLOR HENRY Based on the information you have furnished, the DMDC does not possess
any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
r~r~ J,~.~e,_u~..
Mary M. Snavely-Dixon, Director
Department of Defense -Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense 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 Service Members 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 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 is on active duty, 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.miUfaq/pis/PC09SLDR.htm1. If you have evidence the
person is on active duty 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).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dmdc.osd.miUappj/scralpopreport.do 10/27/2010
, 'Request for Military Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days 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 TARS, Marine Corps ARs and Coast Guard 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) for a
period of more than 30 consecutive days.
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.
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 SCRA
extend beyond the last dates of active duty.
Those who would 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 name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:AAFELCQSIR
https://www.dmdc.osd.miUappj/scra/popreport.do 10/27/2010
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-5169 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF 'RIXeghCM COUNTY:
To satisfy the debt, interest and costs due PNC BANK, NA Plaintiff (s)
From HENRY L. TAYLOR TRUCKING, LLC AND HENRY L. TAYLOR, 8209 FOOTHILL
BLVD #A-286, SUNLAND, CA 91040
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
HUNTINGTON NATIONAL BANK, 650 SMITHFIELD STREET, PITTSBURGH, PA 15212
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $78,535.28
L.L.$.50
Interest $4,621.75
Atty' s Comm %
Atty Paid $133.00
Plaintiff Paid
Due Prothy $2.00
Other Costs:
Date: 11/7/11
(Seal)
REQUESTING PARTY:
Name MATTHEW D. URBAN, ESQUIRE
JILA
avid D. Buell, Prothonotary
Deputy Address: WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
Attorney fbr: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 90963
IN THE CQURF OE COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVII; DIVISION
PNC BANK, NA
Plainti ;f
vs. Civil Action No. 20 1 0-05 1 69 .-'
HENRY L T .YLOkt TRUCKING, LLC; and - R01CP1 i << 19IVd
,rr
14ENRY L TAYLOR 4k P, av(P 000vp
Defendant
I-'-.J'i iINt,''('N N.A'TIONAL BANK, -1p50 S'•???hR?CtckS4
1? a
Garnishee Tittsta?h' c pvi, tsa l
PRAECIPE TO INDEX WRTT OF LXi CLTION
AND ENTER IT IN T1J E..ItT1)-'--:MEN'I' INDEX -?
TO THE PitOTHONOTARY:
Kindly issue a Writ of Execution in the above matter
1. directed to, the Sheriff of ALLEGHENY County:
2. against HENRY L TAYLOR TRUCKING .AND HF,NW,' I. " 'AYLOR, Defendant
3. against HUNTINGTON NATIONAL BANK, Garriishce
4. and enter this Nvrit in the judgment index
(a) against HENRY L TAYLOR TRUCKING AND HENI:Y L TAYLOR, defendant. and
(b) against HI.'NTINGTON NATIONAL BANK, as garnishee.
as a its pendens against real property of the defendant in tip, name of garnishee as follows:
AnY :nd/r;c_all rsonal property belonging to the defend::;?tO i_n ossessio„ of the garnishce(s).
>. Judgment Amount
Interest
cos",
SUBTOTAL:
Costs (t(: be added by Prot? ,... notary):
C)
QMT
MTA 01?
60 09F
1 Lt. Oo `L ((
a, 5(? u Ct
:ZU
$ 78,535.28
$ 4,621.75
$ 83,157.03
1t,EL,rVJAN, WEINBFIRG & REIS CO., L.P.A
Bye-
Matthew I). Urbon, i;squire
PA I.D. 490963
WEL"IAJAW, V1'; Il,13ERG & REIS CO., L.P.A.
1400 Koppers I3r1116,ng
436 Seventh AV nuc
Pittsburgh. PA ? 52 9
(412) 4-34-7955
4??.C b .
cc._
C?6? Io1 Q s aas
Wr,! '-?
?Iv
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Matthew D. Urban, Esquire Attorney for Plaintiff(s)
I.D. No.90963
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 8126533
PNC BANK, NA
CUMBERLAND County C')
Court of Common Pleas -O3 *a _4
MW C-
c„r-
LLC; and
HENRY L TAYLOR TRUCKING -<
,
HENRY L TAYLOR
rC ,
NO. 2010-05169 r
and
HUNTINGTON NATIONAL BANK
Garnishee(s)
AFFIDAVIT OF SERVICE OF WRIT OF EXECUTION
Before me, the undersigned authority, personally appeared Matthew D. Urban, Esquire, who
according to law deposes and says that a copy of the Writ of Execution has been served on the
following garnishee, Huntington National Bank.
1. On or about, November 25, 2011, the Sheriff of Allegheny County served the Writ of
Execution and Interrogatories upon Mike Glyde of Huntington National Bank at 650 Smithfield
Street, Pittsburgh, PA 15222. A copy of the Sheriff Return is attached as Exhibit "I ".
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Matthew D. Urban, Esquire
Attorney for Plaintiff
` Sheriff Return
SHERIFF RETURN
Case No : GD-11-023623
Case Description : PNC Bank N.A. vs Henry L Taylor Trucking LLC
Defendant : Huntington National Bank
Service Address : 650 Smithfield Street Pittsburgh, PA 15222 Allegheny/2
Writ Description : WRIT OF EXECUTION
Issue Date : 11/15/2011
Service Status • Served - Manager / other person authorized to accept
' deliveries of United States Mail
Served Upon : mike glyde
Served By : Wayne Davin
Served on : Friday, November 25, 2011 at 09:39
Service Method : Person In Charge
PNC Bank N.A.
vs
Henry L. Taylor
Henry L. Taylor Trucking LLC
Page 1 of 1
https://dcr.alle henycounty.us/Sheriff/SheriffRetum.asp?CaseID=GD-11-023623&WritID=... 1/4/2012
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: James C Warmbrodt, Esquire Attorney for Plaintiff(s)
I.D. No.42524
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 8126533
PNC BANK,NA
Cumberland County
Court of Common Pleas c
vs.
hCN?"-i L V/ ILOR- I?1
LkL&i CoO
rncv
z?
C-
? ?I
?M
1Ac-Npq L Ifl?op- :?o =,
NO. 2010-05169 ?-- --?
and D p c
HUNTINGTON NATIONAL BANK C )
-J
Garnishee(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly marked the above matter discontinued and ended as to Garnishee(s), HUNTINGTON
NATIONAL BANK, only.
WELTMAN, WEMBERG & REIS CO., L.Y.A.
By
Jame Warmbrodt, Esquire
Atto e for Plaintiff
Sworn to and subsc 'bed
Before me t ay of December, 2011 NNSYLVANI".._
COMMONoNEA Sea
Wen+iy L. Gault, Notary public,
Allegheny County
_ oP P,ttsbur9h fires ]uhy 1!.; 207 4
My C, jjn?ssion E%P
NOTARY PUBLIC
t.?:?moer P,?nnsv{uanla Assrciattor. o.:??E.•?=;,'
+ q.60 P Z A T7`4
8.0 1014U M/10319a58
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