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HomeMy WebLinkAbout12-0964 NEW CUMBERLAND FEDERAL n r.a IN THE COURT OF COMMON &LEM C:? _.r CREDIT UNION OF CUMBERLAND COUNTYuCO r -n rn -=-q r n PLAINTIFF PENNSYLVANIA :Z::u co CD VS. CIVIL ACTION - LAW <CD =-n >C-) SUZANNE M. JONES AND NO. da( 09 - '/ U y ? RONALD M. JONES DEFENDANTS ` 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 OR FOR ANY OTHER CLAIM RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 By: 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 ah?•?t o It'&- sP4 Ck 1o3aq NEW CUMBERLAND FEDERAL THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY PLAINTIFF PENNSYLVANIA V. CIVIL ACTION - LAW SUZANNE M. JONES AND RONALD M. JONES DEFENDANTS NO. COMPLAINT 1. The Plaintiff is the New Cumberland Federal Credit Union with a principal place of business located at 345 Lewisberry Road, New Cumberland, York County, Pennsylvania 17070. Plaintiff is a federally chartered nonprofit credit union. 2. The Defendants Suzanne M. Jones and Ronald M. Jones are adults residing at 110 High Pointe Drive, Rincon GA, 31326-5243. 3. The Defendants are not current members of the Armed Forces. COUNT I: NCFCU LOAN 4. On April 4, 2008 Defendant executed a Loan Agreement attached as Exhibit "A" in the amount of Fourteen Thousand Three Hundred Ninety Five and 74/100 ($14,395.74) Dollars at 11.400% interest. Defendants were the borrowers under this Loan Agreement. 5. The terms of Exhibit "A" required 113 semi-monthly payments of $168.18 and a final payment of $167.03. 6. Defendants failed to make timely payments. 7. Defendants on January 31, 2011 agreed to a Loanliner Subsequent Action statement attached as Exhibit "B" amending the semi-monthly payments to a monthly payment of $254.18 with an interest rate of 11.400% for the remaining balance of $7,647.30. There remains a principal balance due of $6,255.07 plus past due interest at 11.400% with a $1.93 per diem from February 1, 2012. 9. Defendants have made no regular payments despite repeated requests. 10. Pursuant to the Loan Agreement the Defendants agreed to pay all "court costs and reasonable attorney fees" incurred in any collection action. WHEREFORE, Plaintiff respectfully requests entry of judgment in the amount of $6,255.07 (principal plus past interest) at 11.400% interest from February 2, 2012 and a per diem of $1.93 together with all court costs and an award of reasonable attorneys' fees. Respectfully submitted, By: Steven well, Esq4fe' - Ho 1 Law Firm 19 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 02/03/2012 15:30 7177708 HOWELL LAW FIR PAGE 01/11 Verification I verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subiect to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. T verify that I am the President of the New Cumberland Federal Credit Union and that I am authorized to execute this document. $y: Donald Varner . sident N CFCU Date: NDN > c=ff UMON P.0-UM 868 • New Cta tdand, PA 17070-0868 (717) 774-4838 9 1-ND-718.2328 ?? `? ' Vii) LOAN AND SECURITY AGREEMENTS AND DISCLOSURE STATEMENT L04/U4T?2008 IAN NUMBER AMBER GROUP POLICY NUMBER MATURITY DATE 11?t V`t f# 3 037-0619-4 NAME RESS NAME (AND ADDRESS IF DIFFERENT FROM BORROWER 1) SUZANNE M JONES RONALD M JONES 110 HIGH POINTE DR 110 HIGH POINTE DR RINCON GA 31326-5243 RINCON GA 313265243 .......:.. ......... . ANNUAL PERCENTAGE RATE FINANCE CHARGE Amount Financed Total of Payments Total Sale Price The cost of your credit as a yearly rate. The dollar amount the The amount of credit The amount you will have The total cost of your purchase on credit is credit will cost you. provided to you or on paid after you have made $ your behalf. all payments as scheduled. which includes your 11.400 % $ 4,462.54 e $ 14,395.74 $ 19, 171.37 a downpayment of S Your Payment Schedule Will Be: Prepayment: If you pay off early you will not have to Number of Payments Amount of Payments When Payments Are Due pay a penalty. 113 $ 168.18 SEMI-MONTHLY 05/15/2008 Required Deposit: The Annual Percentage Rate does AND 1 $ 167.03 a not take into account your required deposit, if any. ing your mobile home Assumption: Someone bu y Property Insurance: You may obtain property insurance from anyone you cannot assume the remainder of the loan on the want that is acceptable to the credit union. If you get the insurance from us, original terms. you will pay$ N/A Demand: This obligation has a demand feature. Late Charge: All disclosures are based on an assumed maturity of one year. THIS CREDIT UNION DOES NOT ASSESS LATE CHARGES Filing Fees Non-Filing Insurance 9 $ 0.00 N/A Security: Collateral securing other loans with the credit union may also secure this loan. You are giving a security interest in your shares and dividends and, if any, your deposits and interest in the credit union; and the property described below: Collateral Property/Model Year I.D. Number Type Value Key Number $ 0.00 $ 0.00 $ 0.00 Other (Describe) 0.00 0.00 Pledge of Shares $ 0.00 in Account No. $ 0.00 in Account No. See your contract documents for any additional information about nonpayment, default, and any required repayment in full before the scheduled date. CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT. By signing as Borrower, you agree to the terms of the Loan Agreement. If property is described in the "Security"section of the I ruth in Lending Disclosure, you also agree to the terms of the Security Agreement. If you sign as "Owner of Property" you agree only to the terms of the Security Agreement. zz= (SEAU Q X 7. (SEAL) 1 Lod, DATE BORROWER 2 DATE (SEAL) 11 X (SEAL) BORROWER OWNER OF PROPERTY [ WITNESS DATE E] OTHER BORROWER [3 OWNER OF PROPERTY E] WITNESS' DATE Jf NOtory Pulft owe of aIl10Q?0 ?A l? OO1 0 CUNA MUTUAL GROUP, 1999, 2000, 2001, ALL RIGHTS RESERVED I r A . I .. 17 X'7 % 1'l? /? 1 _1 NXXn22 11 AgFRI Credit Union New Cumberland Federal Credit Union Borrower(s) SUZANNE M JONES Loan No. Acct. No. L# 3 Itemization of Amount Financed of Amount Given to You Directly Amount Paid on Your Account Prepaid Finance Charge $ 14,395.74 $ 3,000.00 $ 11,395.74 $ 0 00 Amounts Paid to Othe rs on Your Behalf: (if an amount is marked with an asterisk (*) we will be retaining a portion of the amount.) $ 3,000.00 To 040 41 11,395.74 To REF $ 0.00 To g 0.00 To $ 0.00 To $ 0.00 To $ To $ To $ To $ To $ To $ To $ To $ To in tnls Loan Agreement ("Agreement") all references to "Credit Union," "we," "our," or "us," mean the Credit Union whose name appears above and anyone to whom the Credit Union assigns or transfers this Agreement. All references to "you," or "your" mean each person who signs this Agreement as a borrower. 1. PROMISE TO PAY - You promise to pay $14,395.7?p the Credit Union plus interest on the unpaid balance until what you owe has been repaid. For fixed rate loans the interest rate is 11.400% per year. Collection Costs: You promise to pay all costs of collecting the amount you owe under this agreement including court costs and reasonable attorney fees. L. PAYMENTS - You promise to make Layments of the mount and at the time shown in the Truth in Lendin Disclosure. You ma prepay any amount without ppenalty. you prepay any par of what you owe, you are stlI req (red o make the regular y scheduled payments, unless we gave agreed, to a change in the payment schedule. Because this is a simple i to est loan, if yQu do not make payments exactly as scRecluled, your final payment may be more or I ss than the amount of the final payment that is disclosed. If you elect credit insurance, we will either include the premium in your payments or extend the term of your loan. If the term is extended you will be required to m ke additional payments of the scheduled amount, until what you owe has been paid. You promise to make all payments to the place wilt choos If this loan refinances another loan we have with you, the other loan will be canceled and refill n d QQf hhe d to of his I an. 3. L?AcNf PF??RA 9Y MA?L - If the proceeds of this loan are mailed to you, interest on this loan begins on the date the Ig8n ce d r Wiled to ou. 4. SUgf?Y FeOt??A -This ??greement is secured by all roperty des ribed in the "Security," section of the Truth in ending Disclosure. Property securing other loans you have with us also secures this loan, unlless the property is a dwhlli% A dwelling secures this loan only if it is described in t e ecurit " section o the ruth in Lending Disclosure for this loan. /i Credit Union has a Wsrpl charter: Statutory Lien - If you are in default on a financial obligation to us, federal law ive us the right to apply the balance of shares and dividends in all individual and joint accounts you have with us to satisfy that obligation. After you are in default, we may exercise this right vyithout further notice to you. ?We have a federal char-ter it our name includes the term Federal Credit Union.") /f Credit Union has a state charter, except in Ohio and Rhode Island. Vye have a statutory lien on the shares an dividends and, i any, the deposits and interest in all- individual and joint accounts you have with us and may - - permitted name doi For all be shares an all ioint a 9 our righ under to law. (V1?e . have ncl de the term " (You lei nds and, i any, all to will allow us at you owe vi and your plec :ment Account al tax treatmen Tuture. i nest, an pyou are in e any other aa1 under state or tare cnarter IT our )ral Credit Union." ity for this loan all Dsits and interest in ive with th credit >,ry lien ando , or your in your account(s) cult. The statutory to any Individual nt that would lose aral law if given as 5. DEFAULT - You will be in default under this Agreement if you do not make a payment of the amount required on or C CUNA MUTUAI. ¢?;QUP, 1909,;000. 2001, ALL RIGHTS RESERVED before the date it is due. You will be in default if you break any promise you made in connection with this loan or if anyone is in defat(lt under any security greeme t made in connection with this Agreement. You A ffi In de?ault if you die, file fpr bankruptcy, become insolvent (that is unable to pay your bills and loans as they become due), or if you made any talse or misleading statements in your loan application. You will also be in d-ef ult if something happens that we believe may seriously affect yQur ability to repay what you owe under this Agreemeneor it you are in default under any S. I an a reement ou ave with us. 6. ACTIONAFTER D?FAULT - When you are in default, we may dema d immediate payment qT the entire unpaid balance under this Agreement. You waive any ri ht you have to receive demand for payment, notice of inten? to demand immediate ayment and notice of demand for immediate payment. If we demand immediate payment, you will continue to pay interest at the rate provided for in this Agreement, until what you owe has been repaid. We will also apply against what you owe any shares and/or deposits given as security under this Agreement. We may also axeircise any other rights given by law when you are in is alJt H PERSON RESPONSIBLE - Each person who signs reemen the will be individually and jointly responsible for the entire a ount owed under this A reement. This we can enTorce our rights against aigy one of you I IlYy?oor gg Inst all of you together CRAG - If you are late in making a payment, you i to pay the late charge shown in the Truth in Lending ure. If no late charge is shown, you will not be I one. kY IN ENFORCING RIGHTS - We can del y enforcing Dur rights under this Agreement any number of times losing the ability to exercise our rights later. We can this Agreement against your heirs or legal ntntiVaa ;TIVENESS - If any part of this by a court to be unenforceable, the 11. NUT) ES - NotlCes will be sent t9. you at the most recent ad ress you (lave given us in writing. Notice to any one of you will be notice to all. 12. OTHER PROVISIONS - NXX022 (LASER) -W1 I UM IYAMC U 1 PICK 1 n/.n r nla cy T UNION (Attwh addffl..l sheet(s) If neoprhEDIy) IN I CHEST RATE PRESENT BALANCE MONTHLY PAYMENT OWED APPLICANT OTHER EARS/rgsn $ 1997-0 $ 1;9; M) U, SEARS CBSD $ 1036.0 - $ 68.00 X U WFCB BLAIR CATALOG $ 224.0 $ 11.00 X S WF FIN BAN $ 5068.0 $ 101.00 X U P S E C U $ 4812.0 $ 108.00 X U P S E C U $ 7553.0 $ 150.00 X S WF FIN BAN $ 5068.0 $ 101.00 X U P S E C U $ 7553.0 $ 150.00 X U P S E U $ 4812.0 $ 108.00 X $ $ 1142 00 X $ $ 266 nn X *** EE ATTACHMENT IF APPLICABLE*** $ - $ LIST ANY NAMES UNDER WHICH YOUR CREDIT REFERENCES AND CREDIT HISTORY CAN BE CHECKED: TOTALS $1-96,779.1---$2,35-q.50 WHAT YOU OWN LIST LOCATION OF PROPERTY OR FINANCIAL INSTITUTION MARKET VALUE PLEDGED AS COLLATERAL FOR ANOTHER LOAN OWNED gppLICANT BY OTHER $ $ $ $ $ *** *** $ IF YOU ANSWER "YES" TO ANY QUESTION OTHER THAN x7, EXPLAIN ON AN ATTACHED SHEET APPLICANT OTJIFR 1. ARE YOU A U.S. CITIZEN OR PERMANENT RESIDENT ALIEN? 2. DO YOU CURRENTLY HAVE ANY OUTSTANDING JUDGMENTS OR HAVE YOU EVER FILED FOR BANKRUPTCY, HAD A DEBT ADJUSTMENT PLAN CONFIRMED UNDER CHAPTER 13. HAD PRnPFRTY rnacr1 nscn 1 ronr l no oroneeceecn I-- I I- -, W ec 3. IS YOUR INCOME LIKELY TO DECLINE IN THE NEXT TWO YEARS? 4. ARE YOU A CO-MAKER, CO-SIGNER OR GUARANTOR ON ANY LOAN NOT LISTED ABOVE? FOR WHOM (Name of Others Obligated on Loan): TO WHO M (Name of Creditor): 1?4f'I~ LA]iif1C8 OHIO RESIDENTS ONLY: The Ohio laws unless the Credit Union is furnished a copy of the agreement statement or against discrimination require that all creditors make credit equally available to all creditworthy customers, and that credit , decree, or has actual knowledge of its terms, before the credit is granted or the account is opened. (2) Please sign if you are not applying for this reporting agencies maintain separate credit histories on each individual upon request. The Ohio Civil Rights Commission administers compliance account or loan with your spouse. The credit being applied for, if granted, will be incurred in th i t f with this law. e n erest o the marriage or family of the undersigned. WISCONSIN RESIDENTS ONLY: (1) No provision of any marital property t il l X agreemen , un atera statement under Section 766.59, or court decree under Section 766.70 will adversely affect the rights of the Credit Union SIGNATURE FOR WISCONSIN RESIDENTS ONLY DATE 1'il 1. You promise that everything you have stated in this application is correct to the best of your knowledge and that the above inform ti i 2. If you are applying for a credit card, you understand that the use of a on s a complete listing of what you owe. If there are any important changes you ill i your card will constitute acknowledgment of receipt and agreement to the terms of the credit card agreement and disclosures. You grant us a w not fy us in writing immediately. You authorize the Credit Union to obtain credit reports in connection with this a lication for dit d f security interest in all individual and joint share and/or deposit accounts pp cre an or any update, increase, renewal, extension or collection of the credit you have with us now and In the future to secure your credit card account. When you are In default, you authorize us to apply the balance in received. You understand that the Credit Union will rely on the information in this application and your credit report to make its decision. If you these accounts to any amounts due. Shares and deposits In an Individual Retirement Account, and any other account that would lose special tax request, the Credit Union will tell you the name and address of any credit bureau from which it received a credit report on you, It is a federal crime treatment under state or federal law if given as security, are not subject to the security Interest you have given In your shares and deposits to willfully and deliberately provide incomplete or incorrect information on . loan applications made to federal credit unions or state chartered credit unions insured by NCUA. X (BEAU X (SEAL) y 0 APPLICA S SIGNATURE DATE OTHER SIGNATURE DATE wo X. FK#R ?i EDIT f1YlQ?ti USE t)iIfL1 DATE APPROVED APPROVED SIGNATURE LINE OF CREDIT OTHER OTHER DEBT RATIO/SCORE LIMITS: BEFORE AFTER DENIED $ $ (Adverse Action Notice Sent) e LOAN OFFICER CO ENTS: SI NATURES: ( DATE DATE ;CA k6cL, (fir Ma.,~ PAGE 2 AXX123 (LASER) 27860 By signing below, each of the following applicants certify that they applied for joint credit. Signature /u Date Date Signature -/ 'S d-t- D ( ,.c il; 40 IIMUCl- M! M? T-967 P0002/0004 F-308 ?y" Ik?ll?ir. Subsequent Action I« ?S z2an:cm -j L, 3 fv" a wwE ?(IMMU A )DOW WAMM oM On (date). You apros b ba bound by at t w damns and oardilone of the LOANUNW QVM AWmrwrt and SNU* Agreement, if appk albs. Mm un Wwand #W you may abtsin wtv*rwes wader ire Plan and to © you am obligated to repay all aallatYlte borrowed in ft future by. any joint ban wer on On Plan or O you are oblipaaed to repay all amounts borrowed under the f+fan. Including any amounts owing on this dads. UM.Alt00W W.: Dads Plan Opened: Name(s) of Additional Saw wor(s)t On (date), (Borrower') (Quww or) is released from 0 am liability or O ell forum tad not paw liability am Loot Amount Na %U tan now %%*a auky :lac.! to beoonw inenmd with the a) du=Md below In order for c o erne V be=M etlsoll" you na18t meet aw mortar skgibifMir egtanwrtents stated in the Cedit lttsu??aftwSchaW N pw on atldlrt? oaVarade awe Own 30; ft" after "w date of Vow adattoMoatt you rrwat the Etlidall0a at' puNbns. NO?>C: Ths wisufa ve You're for jug sWL By v%pAny beam, you autor?ta Reller to &W the drasr?gas i fooerlffloift r the rannooe to your of np If you oe need a einoh t°0tx rM. Coverage OW W applies to the snore behmos on Oft 0 atwoouri laen f ) or D open and plan. lnsur+ m rapes are subject to change. Nbu OW pre buowirtg: Sinyis Cr" CIity Joint CM & Disability SNgIe Credit Life Jow Cfo* U116 OPEN-END Coat Per $100 arybur Mongty Loan Balance a d c CLOSED-END Premium sovdula S _e ? a s e s e NAME OF INSURED(S) (Please Print) To pay lnaurance premium, you pgree to: R make more payments of the same amount until what you owe has been repaid. irra ww your monthly payment to S ey slpNnp bailm you aced not to be insured br: ? t3N4e 090 Life Q Joint Credit Ule 0 single Cmdk oiwbility 0 Joint Credit Disability Ntawaartoa on your Loanftbwcou t Na afkave (data). For o wwKl Plana. You wxWs and Qtat all othw Plan SuboocourKs that were Initially o&mw wo csontintte to be oovwed, untese you waive the mane plan. NEW CUMBERLAND FEDERAL, CREDIT UNION, PLAINTIFF V. : SUZANNE M. JONES AND RONALD M. JONES, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA - CIVIL ACTION - LAW C? ...ems..,.. - ,., '..? mrn rti . CIS ? ^7 ? NO. 2012 - 964 CIVIL mac: AFFIDAVIT OF SERVICE OF COMPLAINT ; I hereby certify that on FEBRUARY 17, 2012 a true and correct certified copy of ' a Complaint endorsed with a Notice to Defend was served upon the DEFENDANT RONALD M. JONES and/or his agent as defined by the U.S. Postal Service by U.S. first class mail, certified, restricted delivery as shown on Exhibit "A". Service complies with Pennsylvania Rules of Civil Procedure 404 and 403. Respectfully submitted, Date: March 14, 2012 Commonwealth of Pennsylvania ss County of Cumberland By: ven Howell, Esquire Lowell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 On this, the I Y day of tgk -c* , 2012, before me, the undersigned officer, personally appeared Steven Howell, Esquire, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Affidavit of Service and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. V CR- Notary Public My Commission Expires: COMMONWEALTH OF PENNSYLVANIA 10. 013 Notarial Seal Berit T. Howell, Notary Public New Cumberland eoro, Cumberland 2County My Commieslon Expires Y Member, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA Notarial Seal Berg Nntary Public New Cumrn's -tterland County My Camm.. A %isy 10, 2013 Member, f c::: A6s, : , on of Notaries I? .? a- ,, m L a ?- r-1 Postage $ 03 m I ertified Fee -" ?. C 0 C3 Retum Receipt Fee (Endorsement Requtred) ' J"""" ?' Here S ` G n ? ? ? p ResMcted Delivery Fee (Endorsement Required) ' t' Lys ` 1 t ( l ? Q - 1?5 Y`1 0 Total Postage & Fees $ ! a' ?J /J.-? Q Sent To ?,(,,A N f , (? t? O [`- ' ` = Sfreet Apt %do; or PO Box No. (? //???NN V_l???l,,/MM.?..OO ? ........ ? ? ? ? ? ---- ------------------- City, Stets, Z/P+4 - A .[e.l?fLlrl.. {f[?,cS?r.• {(r _ -------- U.S . Post al Ser vice CE RTIF IED MAIL RE C ' L IF (Dom estic M ail Only ; No Ins urance Cov eragf i?ruvuted) For d -'j" ,..., ;,, t ....,-. . a r ,, . ......_. _ _ Ln ? Postage $ rn Certified Fee QO Retum Receipt Fee (Endorsement Required) P ark ?4ie O Restr?ted Delivery Fee ?? ' O (Endorsement Required) \ G ; , C3 Total Postage & Fees :i?' : ?; ..,02 15/2012 r p a Sent To t,?AuAIX N'! ?v ?? C3 f`- Street, APL No:j ---------- PO Box No. `? J ----C-------------- /A ,I„ (!V /?? ?[ /?_ .. C/ty State, ZIP+4 ? vN - °° ?JI!!W K' t ?u I IF NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW SUZANNE M. JONES AND RONALD M. JONES DEFENDANTS NO. 2012-964 CIVIL rnar ?- z mi - C,)r -<> io © M TO: Ronald M. Jones 113 Summerbrooke Court CD = zZ Clayton NC 27520 = E ..n DATE OF NOTICE: March 16, 2012 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 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 OF THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-31.66 AVISO IMPORTANTE A: Ronald M. Jones 113 Summerbrooke Court Clayton NC 27520 ECHA DEL AVISO: March 16, 2012 USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESETADO CONTRA LISTED. A MEMOS QUE USTED ACTUE DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS IMPORTANTES. USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LAW SI:GUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE. INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 Respectfully submitted, By: Uq Gell Law Firffi 19 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Date: March 16, 2012 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first: class United States Mail addressed as follows: Ronald M. Jones 113 Summerbrooke Court Clayton NC 27520 Suzanne M. Jones 113 Summerbrooke Court Clayton NC 27520 By Date: March 16, 2012 NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF V. SUZANNE M. JONES AND RONALD M. JONES DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA c: CIVIL ACTION - LAW ` _1_ _' CIO 0 c C:3 `. NO. 2012-964 CIVIL ?- PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a DEFAULT JUDGMENT against RONALD M. JONES for his failure to file an Answer to the Complaint served February 17, 2012 by Certified Mail as shown on Exhibit "A-1" in accordance with PA R.C.P. 404 and 403. A Notice of Intention to Take a Default Judgment was filed on March 19, 2012 and served using a U.S. Postal Certificate of Mailing by first class prepaid postage on March 16, 2012 as shown on Exhibit "A-2" (Certificate of Mailing USPS Form 3817 is attached showing service). No answer or response having been filed with the Prothonotary as of March 28, 2012 please enter a Default Judgment in the following amount of $6,813.15 plus all costs: Count I $6,255.07 Interest Count I $ 108.08 ($1.93 Per Diem from February 2, 2012) Fees 450.00 (Attorney Fees per Contract) $6,813.15 plus all costs Respectfully submitted, By: Date: March 29, 2012 given Howelf, Esquire Howell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Attorney for Plaintiff P6. Sb PCL 1039/ .. copy NEW CUMBERLAND FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION, : CUMBERLAND COUNTY PLAINTIFF PENNSYLVANIA V. CIVIL ACTION - LAW SUZANNE M. JONES AND n M Mr, m RONALD M. JONES, F DEFENDANTS NO. 2012 - 964 CIVIL r AFFIDAVIT OF SERVICE OF COMPLAINT 5_.m -'' I hereby certify that on FEBRUARY 17, 2012 a true and correct certified copy of a Complaint endorsed with a Notice to Defend was served upon the DEFENDANT RONALD M. JONES and/or his agent as defined by the U.S. Postal Service by U.S. first class mail, certified, restricted delivery as shown on Exhibit "A". Service complies with Pennsylvania Rules of Civil Procedure 404 and 403. Respectfully submitted, By: ven Howell, h squire 'Howell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Date: March 14, 2012 Commonwealth of Pennsylvania County of Cumberland ss On this, the 1't day of tgk'2-- * , 2012, before me, the undersigned officer, personally appeared Steven Howell, Esquire, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Affidavit of Service and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ??? _?_t L/ &If Notary Public My .Commission Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal ENOWCumberland t T. 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CO,, Stare, ZIP+4 ... ................. .. C co Py NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF V. SUZANNE M. JONES AND RONALD M. JONES DEFENDANTS TO: Ronald M. Jones 113 Summerbrooke Court Clayton NC 27520 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. 2012-964 CIVIL DATE OF NOTICE: March 16, 2012 ,IMPORTANT NOTICE, c ?-31C cn ?" f*, Cj N %D r+• C D'7' 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 RE 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 OP THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 Y AVISO IMPORTANTE A: Ronald M. Jones 113 Summerbrooke Court Clayton NC 27520 ECHA DEL AVISO: March 16, 2012 USTED STA EN EBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARENCENCIA ESCRITA POR SI MISMO 0 A TRAVES DE UN ABOGADO Y SOMETER CO LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESETADO CONTRA USTED. A MEMOS QUE USTED ACTUE DENTRO DE DIEZ EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTRO S DERECHOS IMPORTANTES. USTED DEBE LLEVAR EST DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LAW SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE. INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CALIFICAN. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY BAR CENTER 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 Respectfully submitted, By: H ell Law Firth 19 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court ID 62063 Date: March 16, 2012 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon the party/parties set forth below by postage prepaid, first class United States Mail addressed as follows: Ronald M. Jones 113 Summerbrooke Court Clayton NC 27520 Suzanne M. Jones 113 Summerbrooke Court Clayton NC 27520 B3 Date: March 16, 2012 U.S. POSTAGE M NEW CUMBERLRND.PR Mr I 17pp_Q MAR -T6 12 UMTEDSTAMS AMOUNT POSTAL VI- ?oo0 00052567-0-1 a G V E O J I ' i ??a 1? r a ; o G ? o 0 .l ? a di ? U v ?J a Z r' Lc F- F- Q LL f i V L . CL U.S. POSTAGE PAID NEW CUMBERLAND, PA 17070 (/AIiTFO STATFS MAR 16.'12 AMOUNT POSTAL S.V".. loo0 ?115 0 q t _.. 4 . Ce I r i ? d O m 1~ p '-A IL H I? 'm d 00 4 0 M Z W a N O NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF V. SUZANNE M. JONES AND RONALD M. JONES DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY : PENNSYLVANIA CIVIL ACTION - LAW NO. 2012-964 CIVIL RULE 236 NOTICE OF FILING JUDGMENT (X) Notice is hereby given that a money judgment in the above captioned action has been entered against RONALD M. JONES in the amount of $6,813.15 plus all costs on ?C- , 2012. (X) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. Prothonotary Civil Division BY: Li? If you have any questions regarding this Notice, please contact the filing party: Steven Howell, Esquire Howell Law Firm 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 This Notice is given in accordance with Pa R.C.P. 236. Notice should be sent to: Ronald M. Jones 113 Summerbrooke Court Clayton NC 27520 Suzanne M. Jones 113 Summerbrooke Court Clayton NC 27520