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Home My WebLink About10-6987Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ext. 4151 Attorney for Plaintiff, LIVINGSTON FINANCIAL LLC LIVINGSTON FINANCIAL LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. HAROLD E ARNDT 29 RIVERVIEW DR ENOLA PA 17025-2647 Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION `' No. L - W C110 r..a rya w NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 2559366 PPTCPADI ?D AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des 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. SERVICIO DE REFERENCIAIEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney I.D. #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, LIVINGSTON FINANCIAL LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, HAROLD E ARNDT VS. 29 RIVERVIEW DR ENOLA PA 17025-2647 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. COMPLAINT Plaintiff LIVINGSTON FINANCIAL LLC, claims as follows: 1. The Defendant(s), HAROLD E ARNDT, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) obtained extensions of credit with ELAN FINANCIAL SERVICES, (Original Credit Grantor) agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $2383.50. 4. Plaintiff is the successor in interest of said account having purchased the account in the regular course of business in good faith and value. 5. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2559366 PPTCDBCI WHEREFORE, the Plaintiff, LIVINGSTON FINANCIAL LLC, prays for judgment in its favor and against Defendant(s), HAROLD E ARNDT in the amount of $2383.50, plus costs. Respectfully subm LIVINGSTON FINpI Daniel Santucci, Attorney No. 92800 Gregory R. Dye Attorney No. #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 (800) 850-1079 Dated: October 4, 2010 Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 LIVINGSTON FINANCIAL LLC Gregory R. Dye, Attorney I.D. #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 LIVINGSTON FINANCIAL LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. HAROLD E ARNDT 29 RIVERVIEW DR ENOLA PA 17025-2647 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, H? & MOORE, Dated: October 4, 2010 By: Gregory R. Dye LLER, I XIBSKER 2559366 PPTJCAMI 1111111111111111111111111111111111111111111111111111111111111 IN VERIFICATION the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to au PPTXVERI Exhibit "A" PPTXEXAI VERIFICATION The undersigned hereby verifies that: 1. I am an authorized representative of the Plaintiff and make this Verification on behalf of Plaintiff LIVINGSTON FINANCIAL LLC. 2. 1 reviewed the following [check all that are applicable]: [ ] (a) computerized documents; [ ] (b) hard copy of documents; and [X] (c) other (specify) computerized account data relating to Account No. XXXXXXXXXXXX7502. The foregoing Account was opened on in the name(s) of Defendant(s) HAROLD E ARNDT. 3. Based on my review of the foregoing documents, there is due and payable the principal sum of $2383.50 which is calculated as the original creditor's chargeoff balance less any payments received. The information that I reviewed were provided by the original creditor and or its assignees. 4. Based on my review of the foregoing documents, there are no payments that have not been credited to Defendant(s). 5. The facts set forth in this Verification are true and correct to the best of my knowledge, information and belief. This Verification is made subject to the penalties for making an unsworn falsification to authorites in violation of 18 Pa.C.S. Section 4904. 6?? c)o Signature KRISTA JO HENRY Print Signature Date: PPTXPREI 2559366 { I? I I I I I I I I I I I I I I I I I I I' ? I I I I I I I I I I I I I I I I I I I I 18 I I I V I I I I I I" I I I I I I I I Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney LD #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 610-902-0644 Attorney for Plaintiff, LIVINGSTON FINANCIAL LLC LIVINGSTON FINANCIAL LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, VS. HAROLD E ARNDT 29 RIVERVIEW DR ENOLA PA 17025-2647 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA rN 2 CIVIL ACTION FTI 71 No. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF LIVINGSTON FINANCIAL LLC. Papers may be served at the address set forth below: Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Telephone Number: 1-610-902-0644 ext. 4151 Dated: October 4, 2010 By: BLATT, HA & MOORE, Gregory R. Dye , LEII35KER 2559366 PPTXPEAI 1111111 IN 1111111111111111111111111111111111111111111111111 IN SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?FGicE ?F r?E s??R,?r Livingston Financial LLC vs. Case Number Harold E. Arndt 2010-6987 SHERIFF'S RETURN OF SERVICE 11/04/2010 06:25 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 4, 2010 at 1825 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Harold E. Arndt, by making known unto himself personally, at 29 Riverview Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. rim I *MADA COBAUG , DE TY SHERIFF COST: $41.50 November 05, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF i . ? ' .11 s (C) CountySuite Sheriff. Teleo5oft Inc,. Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci LIVINGSTON FINANCIAL LLC Attorney I.D. #92800 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 LIVINGSTON FINANCIAL LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. HAROLD E ARNDT 29 RIVERVIEW DR ENOLA PA 17025-2647 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10-6987 c-? Q r"n rn IV C3 r c-) __ Ca > ) PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT HAROLD E ARNDT in this matter in the amount of $2383.50 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 12-1-10 by regular mail. A true and correct copy of each Notice is attached hereto. Respectfully submitted, e? +: , BLATT, HASENMILLER, LEIBSKER & MOORE, L Dated: December 14, 2010 By: aniel Santucci 2559366 V4 PPTJPFJI ? ??Sb WNW I MUMIN HIM 11111 IN IN 11111111 IN 010-y ass II N A Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 LIVINGSTON FINANCIAL LLC Gregory R. Dye, Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 LIVINGSTON FINANCIAL LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. HAROLD E ARNDT 29 RIVERVIEW DR ENOLA PA 17025-2647 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10-6987 Defendant(s). AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. BLATT, HASENMILLER, LEIBSKER & MOORE, LLC Dated: December 14, 2010 2559366 PPTJCAMI 1111111111111111111111 N? WIIII IIIII I I II I III II I I I II I I I I I I I I By: //z,-, I niel Santucci Gregory R. Dye LIVINGSTON FINANCIAL LLC Plaintiff, IN THE COURT OF CO'M'MON PLEAS Vs. CUMBERLAND COUNTY, PA HAROLD E ARNDT CIVIL ACTION 29RIVERVIEW DR ENOLA PA 17025-2647 No. 10.6987 Defendant(s). TO: HAROLD E ARNDT Date of Notice: December 1, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A W'AiTTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CU'MBERLAN'D COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BLATT, & MOO LEIBSKER By: 1M5 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2559366 PPTNLRSI gill 1111111111111111111111 IN 1111111 IN 40 a 551z1 3 4 lQ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??? oS ?umbcr???8 S ? OFFICE OF THE SHERIFF Livingston Financial LLC vs. Case Number Harold E. Arndt 2010-6987 SHERIFF'S RETURN OF SERVICE 11/04/2010 06:25 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 4, 2010 at 1825 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Harold E. Arndt, by making known unto himself personally, at 29 Riverview Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. MA DA COBAUG , DE TY SHERIFF COST: $41.50 November 05, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ici Gwmty&Ale Sheriff, Tele .ft, Inc. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6987 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LIVINGSTON FINANCIAL LLC Plaintiff (s) From HAROLD E. ARNDT, 29 RIVERVIEW DRIVE, ENOLA, PA 17025 (I) 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: FULTON BANK, 6520 CARLISLE PIKE, MECHANICSBURG, PA 17050 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$2,383.50 L.L. S.50 Interest $214.32 Attv's Comm °'o Attv Paid $179.00 Plaintiff Paid Due Prothy $2.25 Other GostsSl47.S&2 Date: July 3, 2012 David Q, Buell, Protho (Seal) By: 11,[x) Deputy REQUESTING PARTY: Name : MORRIS SCOTT, ESQUIRE Address: BLATT, HASENMILLER, LEIBSKER & MOORE, LLC 1835 MARKET STREET, SUITE 501 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-1567 Supreme Court ID No. 83587 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION LIVINGSTON FINANCIAL LLC - Plaintiff vs. HAROLD E ARNDT - Defendant Address: oqq ?:%veyvt esz Y. ?,YIS?\4 ,??? l1 v a S TO THE PROTHONOTARY OF THE SAID COURT: f',LED-CIMCE PRC3THt NOTARY 1012 JUL -3 AM 8'- 19 ? Confessed Judgment 1-UM11 lTy ? Other ? SYLVANIA File No. 10-6987 Amount Due L? • 'J Interest Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of . Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description: supply four copies of lengthy personalty list) '? t?n?atilc.-1vS20 tRr?lS?e?I?-e? YVIe?.?W x'16,$25 and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ? (Indicate) Index this writ against the garnishee(s) as a lis pendens against real defendant(s) described in the attached exhibit. / Dale (.O a4 I l Z -- CS ? dg, a y1.SOCh F 9'-a' 00 u a ly 00 tt of a • sc ? a 2559366 PPTXCMPI Signature: Print Name: Address: Attorney for: -? ^s S /g-n ---- Telephone: Z1S - srq- l i`L -- Supreme Court ID No: X53;7 ? ? SO LL T) -P W'4'o? E, zscs'Ltd SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ? `L U ?Ik t' '?"' Sheriff 'r 4 tip'f?Tif1N 17 =e ?4?tix?r izf ?atar??trr?r?jd Jody S Smith JUL ' b 8, $ Chief Deputy 70 1? Richard W Stewart CUMBERLAND COUNTY Solicitor : y ?KE PtNNSYLVANI A Livingston Financial LLC Case Number vs. Harold E. Arndt 2010-6987 SHERIFF'S RETURN OF SERVICE 07/11/2012 11:56 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 1 , 2012 at 1156 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and mo 'es of the within named defendant, to wit: Harold E. Arndt, in the hands, possession, or control of the withi named garnishee, Fulton Bank, 6520 Carlisle Pike, Ste 600, Mechanicsburg, Cumberland County, Pennsylvania 17050, by handing to Jody Lewis, Branch Manager, personally three copies of interrogat ries together with three true and attested copies of the writ of execution and made the contents there of kn wn to her. The writ of execution and notice to defendant was mailed on July 12, 2012 to Harold E. Arndt at 29 Riverview Drive, Enola, PA 17025-2647. SO ANSWERS, July 12, 2012 RON R ANDERSON, SHERIFF am Cline, Deputy (c) CountySuite Sheriff, Teleosoft, Inc.