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HomeMy WebLinkAbout11-9334 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson EiLE' D-Or i' luw Sheriff THE fi ROTHONOTAR V Jody S Smith ? Chief Deputy Ltd 2 JAN " 6 AM $' 4 Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA VNB Loan Services, Inc. Case Number vs. Christin P. Rhoads 2011-9334 SHERIFF'S RETURN OF SERVICE 01/03/2012 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: Christin P. Rhoads, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Christin P. Rhoads. Request for service at 835 Acri Road, Mechanicsburg, Pennsylvania 17050 the Defendant was not found. Deputies were advised, Christin P. Rhoads currently resides at 298 Thrush Drive, Hummelstown, Pennsylvania 17036. SHERIFF COST: $43.00 SO ANSWERS, January 03, 2012 RON R ANDERSON, SHERIFF o toi rltySit '^e?nfi 7oa_InC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA VNB LOAN SERVICES, INC., Plaintiff VS. CHRISTIN P. RHOADS, Defendant TO THE DEFENDANT: : CIVIL-LAW DOCKET NO. \ 1- 8339 NOTICE TO DEFENDANT -l 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. Pennsylvania Lawyer Referral Service Cumberland County Bar Association 100 South Street, PO Box 186 2 Liberty Avenue Harrisburg, PA 17108 Carlisle, PA 17013 800-692-7375 717-249-3166 717-238-6807 RAY OND W. KESSLER, ESQUIRE TRUE COPY FROM RECORD In Te-;timonywhereof, I here unto set my hand a c ;',e seal of &W at Carlisle, Pa. Ti ___?dayaf?, 201/ Praffionotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA VNB LOAN SERVICES, INC., Plaintiff vs. CIVIL-LAW CHRISTIN P. RHOADS, : DOCKET NO. Defendant COMPLAINT The Plaintiff, VNB Loan Services, Inc., by and through its attorney Raymond W. Kessler, Esquire, hereby tiles this Complaint of which the following is a statement: I . The Plaintiff, VNB Loan Services, Inc. is a New York Corporation doing business at 747 Chestnut Ridge Road Suite 201, Chestnut Ridge, Rockland County, New York 10977. 2. The Defendant, Christin P. Rhoads, is an individual residing at 835 Acri Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Defendant obtained a vehicle loan on or about January 4, 2007, from VNB Loan Services, Inc., (hereinafter "original creditor") to purchase a 2006 Ford Explorer, V.I.N. number: 1FMEU72EX6UB04956. 4. Defendant defaulted on scheduled payments and the account was charged-off on December 4, 2008, leaving an unpaid balance of $24,151.56. A copy of the Plaintiff's Statement of Account is attached hereto, incorporated herein and referred to hereafter as Exhibit A. 5. The vehicle was repossessed and sold. After credits from the sale as well as Defendant's payments, the remaining charge-off balance is $24,151.56. A copy of the Notice of Our Plan to Sell Property is attached hereto, incorporated herein and referred to hereafter as Exhibit B. A copy of the Explanation of Calculation of Deficiency is attached hereto, incorporated herein and referred to hereafter as Exhibit C. BREACH OF EXPRESS CONTRACT 6. The above paragraphs are incorporated herein as though more fully set forth at length. 7. In consideration of the extension of credit provided by original creditor through the vehicle loan, Defendant agreed to pay for the money loaned, and additional fees and interest on this account. 8. The reasonable charges and expenses that remain due and owing for the vehicle loan, fees and interest is $24,151.56. 9. Defendant accepted the extension of credit and utilized the vehicle loan without complaint, objection or dispute as to services provided, the prices charged for the same or the costs incurred. 10. Defendant is indebted to the Plaintiff in the amount of $24,151.56. Defendant has failed and refused to pay the aforesaid sum despite frequent demand to do so and the same is now due and owing. it. Defendant's failure to pay is a breach of the express written agreement between the Defendant and original creditor. Pursuant to Pa.R.C.P. No. 1019(i), a copy of the Retail Installment Contract and Security Agreement is attached hereto, incorporated herein and referred to hereafter as Exhibit D. 12. The agreement was signed under seal. WHEREFORE, Plaintiff, VNB Loan Services, Inc., demands judgment against Defendant in the amount of $24,151.56 together with interest, costs, attorney fees and such further and additional relief as this Honorable Court deems just and equitable. Respectfully submitted, Raymon W. Kessler, Esquire PA ID #309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 ,? CCOUNT No 974012572 BORROWER INFORM1LA IT0N CO BORROWER INFORMA'rION <\LI3R1 MT. CHRISTIN RHOADS WILLIAM C. ALBRIGHT 139-70-4259 196-54-4732 7.i R WINTER LANE 904 CHESTER RD ENOLA PA 11025 FNOLA PA 17025 HUMS PHONE ( 71 7) S25- 71'1') LOAN TYPE AN,ricw rED REPO LOSS CONS CREDFI TYPE: DEALER (7) DATF: 711 01 2 00 8 l:MPLUVER \\URA YNONF. FICO APPROVF: 691 CM: `O8 FICO APPROVE: 0 CIO: 179 R E 1 1ST KNOWN LDDRFSS 1 ADDITIONAL COSIGNER --- -- -- INTFItFsT RATE: i0 i0 LOAN DAVE 1; V?001 LAST %(...rIN F 7 DUE VIAI E S V F (, %1, DATE OFFICFR: 00 \441M N' 4 ODE HFRIT \SSV1:NNIFNT DT 2)0 2009 0 IZFPnD4TE ?ISr200R VIN: I( it{U11LX6UA04956 ?l 1FI IC1F. IoN,r1)RDVXPL0'RF.R MILEAGE: 50,347 - - .r I C(A.: 0 00 \V-,RR: FIMF M GAP: ('0000 IIARRISOURG HYUNDAI INC (PA) DATF SOLD. (0!101200 OVER SIIORT: S6956 DATF DESCRIPTION GL AMOUNT CAST AMOUNT (.L BALAN('E ('UST IIA LANCE 711012003 r0 REPOS 000 11,508 72 000 11,508.72 11 1 012 00 8 ANTI( 'IPA IEf) REPO LOSS 2-1,50000 11.>08 72 24,500-00 11,508.72 711012008 INTEREST' 000 896-14 24,500.00 12,40486 711012008 LATE CI IA R( ES 0 00 58 05 24,500.00 12,462.91 711012008 OTHER CHARGFS 0300 ?) 00 24,500.00 12,;92.91 711672008 11 rLE I 1-E 000 2000 24,500.00 ;2,502.91 7/23/2008 SFORM&FFI- 000 21(100 24,500-00 12,7.12.91 111012008 SUES-SERVICE 1-1TLEFEE: 000 1; t4 24,500.00 12,756 25 1 012 1,'2008 AUC110N PEE $291 >0 () 00 000 24,500-00 12,756.25 1012712008 GROSS SALE AMOUN r.$7500 O 00 0 00 24,500.00 12,756-25 10/27/2008 NET SALE PROCEEDS 0.00 -7,212 50 24,500.00 25,543.75 10/27/2008 DEFIC;EN(.'Y IIALANCE DUE 0-00 (HA) 24,500.00 25,543.75 121812008 WARRANTY REFUND 5941 81 941 91 -`)41 RI 23,558.19 24,60294 121812008 GAP REFUND `5.150 38 -450.38 -4>013 21,107.81 24,151.56 EX IBIT FTTLENIENT DATE: SETTLEMENT AMOUNT WAIVED (11Rie r,1. nn1 23,10181 ('1)88 OUST DAL 24,151.56 Friday, February 20, 2001) Page I of d,'VB June 19, 2008 Loan Services, Inc. I mbsidrrrrynft,rire1NffFtCFP0F OUR PLAN TO SELL PROPERTY ('I IRISTIN RHOADS AL13RIG11T 74 R WINTER LANE FNOLA PA 17025 Re: Account Number: 974-012572 Vehicle: 2006 FORD EXPLORER Dear CHRISTEN RHOADS ALBRIGIIT Serial No: I FMEU72EX6UB04956 We have repossessed the vehicle identified above because you broke promises in our agreement. We will sell the vehicle at private sale sometime after July 4, 2008 The money that we get from the sale (after paying our costs) will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. IfNve get more money than you owe, you will get the extra money, unless we must pay it to someone else. You can get the property back at any time before we sell it by paying us the full amount you owe (riot just the past due payments), including our expenses. As of this date, the balance due includes the following: Unpaid Balance: 31,158.72 Accrued Interest: 707.88 Repossession Fees: 350.00 Other charges(incl. Late Fees): 78.05 ESTIMATED TOTAL DUE: $ 32,294.65 (does not include interest from this date, daily storage fees or fees relating to the sale of collateral) To learn the exact amount you must pay, call its at 1-888-647-6470, F,xt 5653. If you want us to explain to you in writing how we have calculated the amount that you owe us, you may call its at 1-888-647-6470, Ext. 5653 or write us at the address below and request a written explanation. We will charge you $25.00 for an explanation if we sent you another written explanation of the arnount you owe us within the last six (6) months. If you need more Information about the sale, call us at the number stated above, or write us at the address below. Please note the vehicle is being stored at: fNURNAI 10NAL RECOVERY SYsrEMS 206 MULBERRY DR. MECIIANICSBURC,. PA 17050#610-534-0404 Storage fees may accrue daily while the vehicle is awaiting sale. Personal property in the vehicle must be claimed within 30 days from the date of this notice, after which time we may dispose of it. We are sending this notice to the following other people who have an interest in the vehicle or who owe money under your agreement. CC WILLIAM C. ALBRIGHT 904 CI IFS ITR RD FNOLA PA 17025 Certified & Regular Mail 7008 0150 0000 0954 1998 7008 0150 0000 0954 1998 & 2001 RI-PA L17.T7FR 717 Cltcslnul Ridge Road. Smie 201 Chestnut Ridge. NY 10977-6225 lel.(8-till 116-01M Fax:(845)t26-10 Xi -(.iLNI ntcrticrl'icc l -'ax (845)426-6116-Collcduons 1611 Free - 1 (888) 6-1741-170 EXHIBIT EXPLANATION OF CALCULA"LION OF DEFICIENCY VNBI,oan Services, Inc. I subsrrharv of f; //ev Vottonal &ink CIIRISTIN RHOADS ALBRIGHT 74 R WINTER LANE FNOLA PA 17025 October 27, 2008 RE: Account No. 974-012572 Collateral 2006 FORD EXPLORER Serial No. I FMEU72EX6UB04956 Dear CIIRIS"FIN RHOADS ALBRIGHT The vehicle referenced above was sold on 10/20/08 and a deficiency balance of $ 25,543.75 exists on your account because we received less money at the sale of the vehicle than you owed to us. We previously notified you about the sale in our letter dated 06/19/08 . fhe breakdown of this balance as of 10127/08 is as follows: Principal amount of your obligation 31,508.72 WNC CPI Premium(s) 0.00 Accrued Interest 896.14 Total amount of your obligation $ 32,404.86 LESS Proceeds of Sale 7,500.00 TOTAL AMOUNT OF YOUR OBLIGATION 24,904.8 PLUS Expenses Repossession & Storage 210.00 Motor Vehicle Fees 33.34 Auction Costs 287.50 Late and Other Charges 78.05 LESS Other Credits (Claim Proceeds) Insurance Credits 0.00 (Warranty) Dealer Refunds 0.00 DEFICIENCY BALANCE DUE . 25,543.75 Future debits, credits, charges, including additional credit service charges or interest, rebates, and expenses may affect the amount of the deficiency. Under the terms of your contract, you are responsible for the payment of this amount. If you cannot ?nake full payment immediately, we may consider a payment plan of reasonable amounts. Please call Repossession Department at 1-888-647-6470 Ext 5653 to discuss a possible arrangement, and to answer any questions you may have. You may also write to us at the address stated below. If we have already sent you a written explanation of the amount you owe us within the past (6) months we will charge you a $25.00 fee. If we do not hear from you within 15 days, we may assign your account to a collection agency or attorney. 'this may result in additional finance charges, legal fees and collection costs to you. We are sending this notice to the following other people who have an interest in the vehicle or who owe money under your agreement. CC WILLIAM C. ALBRIGHT 904 CHESTER RD ENOL.A PA 17025 7008 1140 0000 7507 8404 Certified Mail# 7008 1140 0000 7507 84>4ChestnuMdJJ Road, Suite 201 112 Lctter Chestnut Ridge, NY 10977- 6225 Tel: (845) 426-6100 Fax: (845) 426-6185 - Customer Service Fax: (845) 426-6116 - Collections Toll Free -1 (888)647-4A70 EXHIBIT (I PENNSYLVANIA MOTOR VEHICLE INSTALLMENT SALE CONTRACT, Dated ANNUAL FINANCE Amount financed Total of Payments Total Safe Price PERCENTAGE RATE CHARGE The amount of credit provided The amount you will have paid after you The total cost of your purchase on he cost of your credit as The dollar amount the to you or on your behalf, have made all scheduled payments. credit, including your downpayment a yearly rate credit will cost you II $ ________ (11 1?i) $ 14.3 33. 13 $ 34444.83 $ 18777.`)6 $ 181i'7. `3i? Your PavrnNnr Srhprrule will hr No of Payments Amount of Payments When Payments Are Due i'{ $ 180 - - Monthly, beginning 02/03 f 07 $ },l Security: You are giving a secunty interest in the motor vehicle being purchased. Prepayment: if you pay off early, you will not have to pay a penally. Filing Fees: $ I' • 00 Late Charge: If a payment is late, you will be charged 2% of the portion at the payment which is late tot each month, or part of a month greater than 10 days, that it remains unpaid. See below and any other Contract documents for any additional information about nonpayment, default, any required repayment in full before the scheduled date and prepayment refunds anti penalties, a means estimate In this Contra(itt('i'?'' 1 S1,'i1N(r H (JiWA1 1,.R? we ate ) ?17 I FiIrl1KR'S HILL FM HARRISBURG, F'!A the SELLER. Name Address Co ly I:'11>'f .,1 I'J P RHOAOI , WILLIAM C ALBRIGHF T? You are /IP WIINII R I.N FNC11_A PA 17025 he BUYER(S). Name(s) Addressees) County IF YOU DO NOT MEET YOUR CONTRACT OBLIGATIONS, YOU MAY LOSE THE MOTOF lII 11 VEHICLE AND PROPERTY THAT YOU BOUGHT WITH THIS CONTRACT, AND/OR Zip Code MONEY ON DEPOSIT WITH THE ASSIGNEE. 8{00G I 1 This Contract is between Seller and Buyer. All dl,closures have been made by Seller. Seller intends to assign this Contract to the Assignee- Zip Ccde(s) Itemization of Amount Financed CUi KA11L AND It there is more than one Buyer, each promises, separately and together, to pay all sums due us and to perform all agreements in this Contract TRADE-IN: You have traded in [tie following vehicle: <'.005 FORD F - I50 IV 11311<1 458SNR7G131 1 _ Year and Make Description If a balance is still owing on the vehicle you have traded in, the Seller will pay off this amount on your behalf. You warrant and represent to us that any trade-in is free from lien, claim, encumbrance or security interest, except as shown in the 'Itefrivahon of Amount Financed' as The "Lien Payoff." PROPERTY INSURANCE: You may choose the person through whom insurance is obtained against loss or damage to the Vehicle and against liability arising out of use or ownership of the Vehicle. In this Contract, you are promising to unsure the Vehicle and keep it insured. DEBT CANCELLATION (GUARANTEED AUTO PROTECTION) AGREEMENT IS VOLUNTARY AND NOT REQUIRED AS A CONDITION OF THE CREDIT. This agreement will not be provided unless you sign below, agree to pay the additional charge, and sign the separate disclosure and agreement page, which is part of this Contract. This agreement will apply during the entire term of the Contract this agreement may not cover your entire indebtedness; see the MAXIMUM PROTECTION amount stated in the separate disclosure and agreement. Type of Debt Cancellation Agreement Charge Signature Guaranteed auto protection (GAP) $ 600-M y signin_ i c aranteed auto r lion t/ ?v ignature of Buyer SERVICE CONTRACT OR WARRANTY AGREEMENT IS VOLUNTARY AND NOT REQUIRED AS A CONDITION OF THE CREDIT. The service contract or warranty agreement will not be provided unless you sign the separate agreement with the third party provider, who is not the Seller framed above, and agree to pay the additional charge. This section noes not apply to any warranty that you may receive for which there is not separate charge. CREDIT INSURANCE IS NOT REQUIRED: Credit Life Insurance and Credit Accident & Health (Disability) Insurance are not required to obtain credit, and will not be provided unless you sign below and agree to pay the additional cost(s). Please read the NOTICE OF PROPOSED CREDIT INSURANCE on the reverse side. Your insurance certificate or policy will tell you the MAXIMUM amount of insurance available. All insurance purchased will be tot the term of the credit. We may receive a financial benefit from your purchase of credit insurance. By signing, you select Single Credit Life Insurance, What is your By signing, you select Single Credit Accident & What is your which costs $ age? __ Years Health Insurance, which costs $ _ age? Years Signature of Buyer to be insured for Single Credit Life Insurance Signature of Buyer to be insured for Single Credit Accident & Health Insurance By signing, you both select Joint What are By signing, you both select Joint Credit Credit Life Insurance, which costs $ _. your ages? Accident & Health Insurance, which costs $ What are Percentage your ages? to be insured gontract and/or warroat i e-ti h • , amount of S J 00 paid to IMIC & z+les tax of $ _?1;?t t; ___ ): Cash Price $ , , qr Cash Downpayment $ _ rl r Trade-In Value of Trade-in $ ?11&11'.44 Lien Payoff to: Unpaid Cash Price Balance Optional Debt Cancellation (CAP) $ Cclc' Document Preparation fee $ r Paid to Others on Your Behalf Tc Puhlic Officials toe license, lags and Registration $ C2 r r Lien Fee $ r; (10 Taxes Not Included in Cash rr a (J f? f $ r EXHIBIT b 7G 9:. , .<, >< ,? ,< t atgnatures or nom auyers to ue msurea for joint Lite Insurance V Credit Accident & Health Insurance VEHICLE: You have agreed to purchase, under the terms of this Contract, the following motor vehicle and its extra equipment, which is called !he 'Vehicle' In this Contract- N/(j Yell 3A M-Lk-t Stan Body ?Lul No. CA Truck Too Ca i Sri Number !-JR(.R (RK lF;1F(11?FX(?I1I0??}?>1 Equipped A T. P S. _ AM-f M Stereo . 5 Slid. Other with A C _ P.W. AM-f M Tape -Vinyl Top - ASSIGNEE: We may assign this Contract and Security Agreement to a sales finance company which is the "Assignee.' If the Assignee assigns the Contract to a subsequent assignee, the term also refers to such subsequent assignee. After the assignment, all rights and benefits of the Seller in this Contract and in the Security Agreement shall belong to and be enforceable by the Assignee. The Assignee will notify you when and if Seller makes an assignment. VALLEY NATIONAL BANK, 1445 Valley Road, Wayne, NJ 07470 CO-SIGNER: Any person signing the Co-Signer's Agreement below promises separately and together with all Co-Signer(s) and Buyer(s), to pay all sums due and to perform all agreements to this Contract Co-Signer will not be an Owner of the Vehicle. CO-OWNER: Any person signing the Co Owners Security Agreement below gives us a security interest in the Vehicle and agrees separately and together with all Co•Ownei(s) and Buyer(s), to perform all agreements in the Security Agreement and all other parts of this Contract except the 'Promise to Pay section. TERMS: The terms shown in the boxes above are part of this Contract For To $ For I)t If).C)C) r. To ? For >t 15.UQ ` +' i u fo 3 For To $ For , N/A To For Amount Financed $ We may retain a portion of amounts marked' PROMISE TO PAY: You agree to pay us the Total Sale Price for the Vehicle by making the Cash Downpayment and assigning the Trade-In, it shown above, on or before the date of this Contract, and paying us the Amount Financed plus interest. You promise to make payments in accordance with the Payment Schedule. You promise to make payments on or before the same day of each month as the first payment due date. You agree to pay all other amounts which may become due under the terms of this Contract You agree to pay the Seller or Assignee costs of suit. You also agree to pay reasonable attorneys' fees if Seller or Assignee hires an attorney to collect amounts due under this Contract or to protect or get possession of the Vehicle. You agree to make payments at the place or to send payments to the address which the Assignee most recently specifies in the written notice to you. The Annual Percentage Rate may be negotiable with the Seller. ADDITIONAL DISCLOSURES, TERMS AND CONDITIONS: The Seller may assign this contract and retain its right to Disclosures: Before signing this Contract, be sure that you receive and read the Disclosure to receive a part of the Finance Charge. Buyer. Terms and Conditions: Before signing this Contract, be sure you receive and read the following, it marked X, which are additional pages to and part of this Contract. IM This Contract continues on the reverse side. p Debt Cancellation (guaranteed auto protection) separate disclosure and agreement By signing below, we agree to sell the Vehicle to you under the terms of this Contract. SELLER BY: NOTICE TO BUYER-DO NOT SIGN THIS CONTRACT IN BLANK. YOU ARE ENTIT D TO AN EXACT COPY OF THE CONTRACT YOU SIGN. KEEP IT TO PROT C 0 R LE L BUYE (SEAL) L) I L (-? 4 / Bate . L° - BUYF (SEAL) _--- U p ( ale - /U 4 / Date CU-SIGNER: YOU SHOUr1EAD TE NOTICE TO CO-SIGNFR, WHICH IIAS BEEN GIVEN TO YOU ON A SEPARATE DOCUMENT, BEFORE A"U SIGNING TTIE CO-SICNE NT. CO-SIGNER'S AG ou, the person (or persons) signing below as "Co-Signer," promise to pay to its all sums due on this Contract and to perform all agreements in this Contract. You intend to be legally bound by all the terms of this Contract, separately ind together, with the Buyer. You are making this promise to induce us to make this Contract with the Buyer, even though we will use the proceeds only for the Buyer's benefit. You agree to pay even though we may not have made any prior demand for payment on the Buyer or exercised our security interest. You also acknowledge receiving a completed copy of this Contract. Co-Signer's Signature SEA Address Date Co-Signer's Signature Address Date CO-OWNER'S SECURI rY AGREEMENT: You, the person signing below as "Co-Owner," together with the Buyer or otherwise being all of the Owners of the Vehicle, give us a security interest in the Vehicle identified above. You agree to be bound by the terms of the Security Agreement and all other parts of this Contract except the "Promise To Pay" section. You are giving us the security interest to induce us to make this Contract with the Buyer, and to secure the payment by the Buyer of all sums clue on this Contract. You will not be responsible for any deficiency which might be due after repossession and sale of the Vehicle. _ (a CA LAD I r II\I r "' 1`'rrcrr l C nR I'M C. IC??C tFi Lo n n t-r r .ter Co-Owner's Signature Address D ttC /r?/ BUYER, CO-SIGNER AND CO-OWNER, IF APPLICABLE, ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS CONTRACT AT THE TIME OF SIGNING, INCLUDING THE ADDITIONAL DISCLOSURES AND PAGES LISTED IN, THE SECTION ;BALLED ADDITI,OVAL QWLO8ti1tES. TERM AND CONDITIONS. Ili PP11'"'A, R; ;AUNI)At INIC ft' - `? - v BUYER / CO-SIGNER COSIGNER OR CO-OWNER NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION. BANCONSLIMER FORM PA 1230C-StC (21041 ORIGINAL - White • DEALER COPY - Canary - BORROWER'S/CO-SIGNER'S COPY Pink - COPY foidenrod o 2004 BANCONSUMER SERVICE. INC. VERIFICATION OF COMPLAINT AGAINST CHRISTIN P. RHOADS The undersigned verifies that the statements made in the foregoing Complaint are true and correct based to the best of his/her knowledge, information and belief and understands the statements therein made are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. c't PrAn,',l L Goc1241r°L PT-ef , el f„",- ?3 Printed name and title: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA VNB LOAN SERVICES, INC., Plaintiff VS. CIVIL-LAW CHRISTIN P. RHOADS, : DOCKET NO. Defendant AFFIDAVIT OF NON-MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments, and has not been in such service within thirty days hereof. Dated this 1 ? day of OfGa,4 _,2011 Raymond W. Kessler, Esquire PA ID #309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Far: 570-387-6474 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act 1W Page 1 of 2 Dec-07-2011 06:40:16 4(. Last N First/Middle Begin Date Active Duty Status Active Duty End Date Service A enc ame g y CHRISTIN Based on the information you have furnished, the DMDC does not possess RHOADS P 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). 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.mil/fag/pis%PC09SLDR.htinl. 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. 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 U SC § 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 RDAs. 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:2T2H77OUNF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA VNB LOAN SERVICES, INC., Plaintiff vs. CIVIL-LAW CHRISTIN P. RHOADS, : DOCKET NO. Defendant CERTIFICATION OF ADDRESSES I certify that the precise addresses of Plaintiff and Defendant(s) are as follows: Plaintiff. VNB Loan Services, Inc. 747 Chestnut Ridge Road, Suite 241 Chestnut Ridge, NY 10977 Defendant: Christin P. Rhoads 835 Acri Road Mechanicsburg, PA 17050 Respectfully submitted, Rayrf6nd W. Kessler, Esquire PA ID #309802 36 West Main Street Bloomsburg, PA 17815 Phone: 570-387-1873 Fax: 570-387-6474 IN THE COURT OF COMMON PLEAS OF CUMBERLANIOCCR94MTHONOTARY COMMONWEALTH OF PENNSYLVANIA 2012 JAN 20 PM I, 06 VNB LOAN SERVICES, Plaintiff vs. CHRISTIN P. RHOADS, Defendant CUMBERLAND COUNTY PENNSYLVANIA : CIVIL-LAW DOCKET NO. 11-9334 PRAECIPE TO WITHDRAW COMPLAINT To The Prothonotary: Please withdraw the complaint filed by the Plaintiff, VNB Loan Services, against Defendant, Christin P. Rhoads. Respectfully Submitted, Raymond W. Kessler, PA ID 309802 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone 570-387-1873 Fax 570-387-6474