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HomeMy WebLinkAbout10-6929~~~~~ E~jgIT A ~~~ ,. ~~ ~i~ Exhibit C SHERIFF'S OFFICE OF CUMBERLAND COUNTY t ` Ronny R Anderson ' Sheriff ?? at?r??brrr I ? F ?b Jody S Smith ' Chief Deputy 1' ? °' of Richard W Stewart Solicitor OFFICE OF TNN $"ERIFF Pennsylvania State Employees Credit Union Case Number vs. 2010-6929 Matthew D. Snyder (et al.) SHERIFF'S RETURN OF SERVICE 11/01/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Jodi L. Snyder, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 11/03/2010 07:10 PM - William Cline, Corporal, who being duly sworn according to law, states that on November 3, 2010 at 1910 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Matthew D. Snyder, by making known unto himself personally, at 497 Lexington Avenue Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. LLIAM CLINE, DEPUTY 11/10/2010 Dauphin County Return: And now, November 10, 2010 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Jodi L. Snyder the defendant named in the within Complaint and Notice and that I am unable to find her in the County of Dauphin and therefore return same NOT FOUND. Tina Myers, current resident of 5073 Bass Lake Drive, Apartment 101, Harrisburg, PA 17111 advised Deputies, Jodi L. Snyder does not live at this residence. SHERIFF COST: $75.50 November 16, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) COUntySuite Shenff. Teleosott. Inc. Mtfio of the r*4criff William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PENNSYLVANIA STATE EMPLOYEES CREDIT UNION VS JODI L SNYDER Sheriff s Return No. 2010-T-3371 OTHER COUNTY NO. 106929 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for JODI L SNYDER the DEFENDANT named in the within COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, NOVEMBER 10, 2010. PER TINA MYERS, RESIDENT, DEFT DOES NOT LIVE AT 5073 BASS LAKE DRIVE, APT 101, HARRISBURG, PA 17111 Sworn and subscribed to So Answers, before me this 12TH day of November, 2010 Q ;l* ? -)P*2 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 Sheriff of Dauphin ounty, Pa. By Deputy Sheriff Deputy: T WONG Sheriffs Costs: $58 11/4/2010 ORIGNAL BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 2018 BEC -7 dM I1: 36 CUMBERLAND COUNT PENNSYLVANIA Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. MATTHEW D. SNYDER and JODI L. SNYDER, FILED-OFFICE OF THE PROTHONOTARY Defendants COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 2010-06929 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned action. Dated: I I k )? (c) 3068224.1 BARLEY SNYDER LLC By: awn M. Long, quire Attorney for Pla' tiff Pennsylvania S ate Employees Credit Union Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 CN9k slo•c° ek* asav? if ?; ORIGINAL BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 No. 10-6929 Civil Term FILED-OFFICE T? 2 11 JAN -3 PSI 14: I ;? l? Vy ERL'A'T/3jl O qCi U,.' Ty NIA Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. MATTHEW D. SNYDER AND JODI L. SNYDER, Defendants COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 10-6929 Civil Term PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and against Defendant, Matthew D. Snyder, for want of an answer in the amount of $11,049.80 plus costs of suit. (X) 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 Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. Praecipe for Default Judgment (Cumberland) - PSECU_ Matthew D Jodi L Snyder ,44 C4fl 45- ?? k kh No. 10-6929 Civil Term (X) Pursuant to Pa. R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date: Pennsylvania State Em 126 East King Street Lancaster, PA 17602 717.299.5201 Credit Union NOW, a [,lit IM ?j , 201[) JUDGMENT IS ENTERED AS ABOVE. BARLEY SNYDE?t LLC By: awn M. Long, Es i Court I.D. No. 8377 Attorneys for Plain ff, Praecipe for Default Judgment (Cumberland) - PSECU_ Matthew D Jodi L Snyder No. 10-6929 Civil Term BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 Attorneys for. Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. MATTHEW D. SNYDER AND JODI L. SNYDER, Defendants COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 10-6929 Civil Term PROOF OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF LANCASTER . ss. Colleen Brelje, Paralegal, being sworn according to law, deposes and says that she served a true and correct copy of the 10-day Default Notice upon Matthew D. Snyder, 94 Oneida Road, Camp Hill, Pennsylvania 17011 by regular mail on December 2, 2010 at 5:00 p.m. Sworn to and subscribed before me this !!?L day of December, 2010 BARLEY SNYDER LLC r> By: Colleen Brelje, Paralegal 126 East King Street Lancaster, PA 17602 717.299.5201 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial sell 3oAnn F. Dlpoway, Notary PubNc Qty of Lancaster, Lancaster County My C?onxnlsMM 64tres Dec. 15, 2013 3077382_1 Mangy, PenwiftWa Assoftw of Notaries No. 10-6929 Civil Term BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. MATTHEW D. SNYDER AND JODI L. SNYDER, Defendants COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 10-6929 Civil Term To: Matthew D. Snyder 94 Oneida Road Camp Hill, PA 17011 Date of Notice: December 2, 2010 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE 30773821 No. 10-6929 Civil Term THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800.999.9108 BARLEY SN By: ire Shawn M. Lon/aintiff, Troy B. Rider, Court I.D. No. 206319 Attorneys for P Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17603 717.299.5201 30773821 OR I C3 9NAL BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 No. 10-6929 Civil Term Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. MATTHEW D. SNYDER AND JODI L. SNYDER, Defendants COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 10-6929 Civil Term AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE, PURSUANT TO "SOLDIERS AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940 The undersigned, Shawn M. Long, Esquire, doth depose and say that Matthew D. Snyder, Defendant is not in the military service of the United States of America, based on the following facts: Age of Defendant is unknown; present place of employment is unknown; present place of residence is: 94 Oneida Road, Camp Hill, Pennsylvania 17011, as of the date of this affidavit. ADDITIONAL FACTS, if any. The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S., §4904, relating to unsworn falsification to authorities. BARLEY SNYDER LLC By: Shawn M. Long, Esquire Attorneys for Plaintiff Court I.D. No. 83774 126 E. King Street Lancaster, PA 1760 717.299.5201 Praecipe for Default Judgment (Cumberland) - PSECLI_ Matthew D Jodi L Snyder ORIGINAL No. 10-6929 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OFFICE OF THE PROTHONOTARY CARLISLE, PA TO: Matthew D. Snyder Defendant YOU ARE HEREBY NOTIFIED that Pennsylvania State Employees Credit Union has caused a judgment by default to be entered against you with the Prothonotary of Cumberland County. The judgment was entered on 1 /3 // t _, to No. 10-6929 Civil Term with the Court of Common Pleas of Cumberland County - Civil Division. The judgment is in the amount of $11,049.80 plus costs of suit. PROTHONOTARY By: Deputy erk 30880651 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy i=ILE0-Q i IL t ,:_ F Richard W Stewart Solicitor Pennsylvania State Employees Credit Union vs. Matthew D. Snyder (et al.) SHERIFF'S RETURN OF SERVICE 2'U 11 JM1 12 A V, 9: 5- 3 I'?. MBEPcLAi'II a L?It.I#? . . PE NSYLVA11A Case Number 2010-6929 12/10/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Jodi L. Snyder, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Complaint and Notice according to law. 12/21/2010 11:05 AM - York County Return: And now December 21, 2010 at 1105 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jodi L. Snyder by making known unto herself personally, at 705 Quaker Circle, Apartment 4, Lewisberry, Pennsylvania 17339 its contents and at, the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 SO ANSWERS, January 07, 2011 RON W ? R ANDERSON, SHERIFF SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuedeber Sheriff Reuben B Zeager Chief Deputy, Operations PETER J. MANGAN, ESQ. Solicitor Richard E Rice, II Chief Deputy, Administration PENNSYLVANIA STATE EMPLOYEES CREDIT UNION vs. JODY L. SNYDER Case Number 10-6929 CIVIL SHERIFF'S RETURN OF SERVICE 12/21/2010 11:05 AM -DEPUTY BRET NEWCOMER, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN CIVIL ACTION (CICA) AND NOTICE BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: JODY L. SNYDER AT 705 QUAKER CIRCLE, APARTMENT 4, LEWISBERRY, PA 17339. BRET NE OMER, DEPUTY SHERIFF COST: $63.00 January 04, 2011 SO WERS, Q/_? El-___-?1 A-xji RI RD P UE LEBER, ERIFF ---------------- -- --------------------------------------------------- ..------------ --------------------------------------------- NOTARY Affirmed and subscribed to before me this 4th day of JANUARY 2011 (c) CountySuite Sheriff.. Teleosoft.. In NCTARI AL LISA L. THCR?' '?ITAR`? °UB' I'. Iv No. 10-6929 Civil Term MM -," -<> cn ci r ' --a , . C3 . T - CD BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. MATTHEW D. SNYDER AND JODI L. SNYDER, - Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 10-6929 Civil Term PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and against Defendant, Jodi L. Snyder, for want of an answer in the amount of $11,049.80 plus costs of suit. (X) 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 Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. 3128652 ?d 0 ly. 06 Ck ?lT53a *?? a56ip No. 10-6929 Civil Term (X) Pursuant to Pa. R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. A BARLEY SNYDER LLC Date: ? By: NOW, ??, 15 , 2011 JUDGMENT IS ENTERED AS ABOVE. Shawn M. Long, E quire Court I.D. No. 83 74 Attorneys for P intiff, Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17602 717.299.5201 Prothonotary/Clerk, Civil Division By: 1 , Deputy ;128652 No. 2010-06929 BARLEY SNYDER LLC Shawn M. Long, Esquire Troy B. Rider, Esquire Court I.D. No. 83774; 206319 126 East King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. MATTHEW D. SNYDER AND JODI L. SNYDER, Defendants COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 2010-6929 To: Jodi L. Snyder 705 Quaker Circle Apt. 4 Lewisberry, PA 17339 Date of Notice: January 18, 2011 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU 31105311 No. 2010-06929 THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 800.999.9108 BARLEY By: Shawn M. ong, Esquire Troy B. ider, Esquire Court I. . No. 83774; 206319 Attorneys for Plaintiff, Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17603 717.299.5201 31105311 No. 2010-06929 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. MATTHEW D. SNYDER AND JODI L. SNYDER, Defendants COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 2010-06929 PROOF OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF LANCASTER : ss. Colleen Brelje, Paralegal, being sworn according to law, deposes and says that she served a true and correct copy of the 10-day Default Notice upon Jodi L. Snyder, 705 Quaker Circle, Apt. 4, Lewisberry, PA 17339 by regular mail on January 18, 2011 at 5:00 p.m. BARLEY SNYDER LLC By: Colleen Brelje, Paralegal Swom-tQ and subscribed be ore me 126 East King Street this 1 ayqf? 000 , 2011 Lancaster, PA 17602 717.299.5201 c C?1 Notary Public COMMONWEALTH OF PENNSYLVANIA Notwlal Seat Usa Oesano, Notary Public City of Reading, oerks County 3110531 1 Commission Expires may 12, 2014 '"3nla 4ssodatlon of Notaries No. 10-6929 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OFFICE OF THE PROTHONOTARY CARLISLE, PA TO: Jodi L. Snyder, Defendant YOU ARE HEREBY NOTIFIED that Pennsylvania State Employees Credit Union has caused a judgment by default to be entered against you with the Prothonotary of Cumberland County. The judgment was entered on 3 -t s - I , to No. 10-6929 Civil Term with the Court of Common Pleas of Cumberland County - Civil Division. The judgment is in the amount of $11,049.80 plus costs of suit. PROTHONOT By: Depu 3128652 No. 10-6929 Civil Term BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 717.299.5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. MATTHEW D. SNYDER AND JODI L. SNYDER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 10-6929 Civil Term AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE, PURSUANT TO "SOLDIERS AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940 The undersigned, Shawn M. Long, Esquire, doth depose and say that Jodi L. Snyder, Defendant is not in the military service of the United States of America, based on the following facts: Age of Defendant is unknown; present place of employment is unknown; present place of residence is: 705 Quaker Circle, Apt. 4, Lewisberry, PA 17339, as of the date of this affidavit. ADDITIONAL FACTS, if any. The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S.. §4904, relating to unsworn falsification to authorities. BARLEY SNYD R LLC By: Shawn M. Long, Es 1 Attorneys for Plai if Court I.D. No. 83 74 126 E. King Street Lancaster, PA 17602 717.299.5201 3128652