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Home My WebLink About12-1715THO Jay C. Scheinfield, Esquire Atty. I.D. #23880 8234 West Chester Pike Upper Darby, PA 19082 (610) 853-0300 L U 9 L MAR 19 AM 10: 50 L"'' C? {!IuERLAND COUNTY PENNSYLVANIA Attorney for Plaintiff SUNTRUST BANK 1030 Wilmer Avenue Richmond, VA 23227 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 19 -1-715 OV0 MAE CHA RYAN 1210 Musket Lane Mechanicsburg, PA 17050 Defendant (s) 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 an 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. LaMk ?klb& 750 aO? 9-4o?'V 571A 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 Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 2 Jay C. Scheinfield, Esquire Atty. I.D. No. 23880 8234 West Chester Pike Upper Darby, PA 19082 (610) 853-0300 SUNTRUST BANK 1030 Wilmer Avenue Richmond, VA 23227 Plaintiff VS. MAE CHA RYAN 1210 Musket Lane Mechanicsburg, PA 17050 Defendant (s) COMPLAINT NO. 1. Plaintiff, SunTrust Bank, is now, and at all times mentioned in this complaint was, a corporation organized and existing under the laws of the State of Georgia, with a mailing address of 1030 Wilmer Avenue, Richmond, VA 23227. 2. Defendant, MAE CHA RYAN, is an adult individual residing at 1210 Musket Lane, Mechanicsburg, PA 17050. 3. On or about June 27, 2008, Sutliff Hummer and Defendant entered into a written Credit Sale Contract and Disclosure Statement (the "Agreement"), a copy of which is attached as Exhibit "A" and incorporated by reference. The Agreement provided for the sale of a 2006 Cadillac Escalade. The vehicle described in the Agreement was delivered under the terms of the Agreement Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW 3 on or about June 27, 2008. 4. Subsequently, Sutliff Hummer assigned the Agreement to Plaintiff. 5. Under the terms of the Agreement, Defendant was required to make payments in the amount of Six Hundred Fifty & 26/100 ($650.26) Dollars per month for a period of Seventy-two (72) months. Defendant is in default under the terms and conditions of the Agreement due to her failure to make payment when due. 6. Sutliff Hummer has performed all of its obligations under the Agreement in that it made timely delivery of the vehicle to Defendant. 7. On or about February 11, 2010, Defendant entered into an Extension of Payment Agreement ("Extension Agreement") with Plaintiff extending the maturity date of the loan to July 27, 2014. A true and correct copy of the Extension Agreement is attached hereto as Exhibit "B". 8. Pursuant to the terms of the Agreement, Plaintiff took possession of the 2006 Cadillac Escalade by repossession as a result of Defendant's default. 9. On April 23, 2010, Plaintiff mailed written notice to the Defendant at her last known address, informing the Defendant that Plaintiff intended to dispose of the vehicle at private sale, a true and correct copy of which is attached hereto as Exhibit "C". 10. At a sale held on June 9, 2010, Plaintiff sold the collateral for $17,500.00. 11. Under the provisions and terms of the Agreement, Plaintiff is entitled to reasonable attorney's fees as damage occasioned by the default of the Defendant and such as may be approved by the court. 12. Subsequent to the sale of the vehicle, Plaintiff notified Defendant that a deficiency balance remained due and owing to Plaintiff as more specifically set forth in the written notice sent to Defendant on March 19, 2011, a true and correct copy of which is attached hereto as Exhibit 4 «D" 13. Pursuant to the terms of the Agreement, the balance due and owing Plaintiff is $11,960.69, plus per diem interest of $3.12 from June 10, 2010. WHEREFORE, Plaintiff demands judgment against Defendant, MAE CHA RYAN, in the amount of Eleven Thousand Nine Hundred Sixty & 69/100 ($11,960.69) Dollars, attorney fees, interest at $3.12 per diem from June 10, 2010, and cost of suit. Date: 3 t ? -to ( v nemriela, tJsquire for Plaintiff 5 1, 1 , state that I am the D eCt IJ-%f Suntrust Bank, the Plaintiff herein, that I am authorized to make this verification on its behalf, and that the facts set forth in the foregoing Complaint that are within my personal knowledge are true and correct, and that based upon information I have received from others I believe to be true and correct. I understand that my statements are made subject to 18 Pa. C.S. Sec. 4904 providing for criminal penalties for unsworn falsification to authorities. Date: I?Ia?V? 1 Z?iZ Rudolph e 1'? ck ????(r 1 L; ? -7)01 1 s VERIFICATION C:1_ TYESHA WALKER Notary Public Commonwealth of Virginia 7094012 My Commission Expires Jun 30, 2015 6 EXHIBIT "A" Credit Sale Contract and SU1TRUSP Disclosure Statement (Pennsylvania) 1-800-821-7006 Ifer (Dealer's Name and Address) Buyer WW Co-Buyer) Name and Address SUTLIPF HUMMER 1MAE ude CHARYANp Code) 64621CARLISLE PIKE 1210 MUSKET LANE MECHANICSBURG, PA 17050 MECHANICSBURG, PA 17050 In this convaa'due words'ym' and 'you," mean the buyer, and refer to each person or entity who signs below as Buyer or Cosigrw.'We", 'us and "our mean the Sell, or SwT st Bank after it buys this contact. You hereby purchase from us the vehicle described below (the 'vehicle'). You have received and accepted the vehicle, which will be used primarily for pr-'-t Aaedv er hotBid!dd purposes unless the fdbwing boa is diecked: O vehicle use is primarily for business purposes. You may buy the vehicle f« cash is .r:m -I- is shown belay as 'Trial Site Price.' By signing this cordract you choose t -5aag ts????????????? Payment Terms: You promise to pay us the Amount Fin ;hive monthly install- ments commencing the due date specified in the ng an Sc ill. You will also pay to us any other changes imposable under this contract, s. iicie. New catheacc ANNUAL PREENTAGE PATE gNANCe CNARCf A.-Ant sn.-d Tow d h)mhenb Tab) Sale Mee The cad of your credit a A the dopx arhwrm the The amount of credit The amour you will hale paid The told! cost of your pumh- ready hate. oed'n will wit you. prw;ded to you or on your after you have made all on creek;ncl ding your behalf. payments As scheduledr dowrtpaymnN of f 2,562.96 ;., O. SA% f it 7]A ]? f -Apt 5'. no f As 0'. 77]' f 40,299-1 69 We 17rrgr. t a payrtAmt Is mate than 10 days late, yo., will Pay Alast charge of 2% Security labrel Wu ate rMnhg A security interest in the vehicle bestg x cha std dCW Pamtmt. nd In all satin and nhackirhg acmhaxs tut we i.W br you, except IRA and PnWysnnd. If you pay off early, you will rho haw An pay a penalty, Keogh accamts and pemipn)sends. Additional 4d«nWiata See the aM aide of this contract for more idohmabn inclu&rat inf«nWion about non paynw{ defaut. any repuind repayment in fun befne the scheduled date and secu ty ;Nee W. nUUZAnoN OF AMOIJW FINANCED 1 Cash Sale Pri-Consisting of (A) Cash Price of Vehicle Sold s 33.447.18 (9) Separate Clhahge, if any, for DeRwry, Iruullauon. Repair or 00. Services .S NI -$ 33,447,10) 2 Tbal Downwyment• Net Trade-in S N/A + Cute Dovinuymems 2,562.96 Trad.inba f 2,562.90) Year Make Model 7 Unpaid Balance of Cash Sale Price ll min«2) f in. RRA 7?) A Otc+Ohagus Irc tiding Armrb Paid b Otlhas on Your &haN, hit may Rotain a PoAion d These Amours. 'A CondOptk.WMedrnlol E1?bppvvCoverage Paid to the Cmtpany Named&I- CovedngCMainAteclrmW RS Urc 036/0036000 S 2.400 00 •'B Cor Optional Credit Irmrahhce br tlhe T rib contrao P b due M«ance CornPanY « Compnles Named Be X` fef N/A Daahility, Accident and lleaNh s N/A s_ N/A C Tares Net Inclhnded in Cash Price s 2,150.8 3 D Fninaandit-rdw Fen $ 22.50 ENCUMBRANCE s 5.00 E Govenurherv License, Title, andMr R?istratorh Fro f 26.45 F opts Clwae (sen« Parser idehdfv who win rcdve oavrrhmt and deaame wm«H f_ N/A optional Debt GncNladon Catba t b for S- N/A ro SUTLIFF HUMMER for DOCUMENTATION FEES g_ 55.00 Twl ocher Chatees and Amcure Paid to Oil- en rat Behalf $ 4.659.74 ) 5 A t Fnwheed (Rheas! Amount Firo e&(3141 f 35,544,00) Qtems 6, 7 atl B one A f 11.274.76) (w)aited assumlhhg 7 TWI of PavmetsIII- Balance) 6+b1 y«r make au g 46, 818.72,1 payments onthe d Poynter Sdstdule: Irhrillnstat II 50.2fid i 72 of date and m the f 650.26 each, monthly. beginning and doe 1 _ amounts sd,.kd d. on the dates shown in the p,4- shdh d.A. inhttase. t arty i«orace is dhecked below, tit polcle «cmtghaea brad M the kea rwar, eanpanl will decdbe the terms and conditions. Dpiaalorf hundoCwe-agawnaanu!aajadera!dmeadtntaaMdahauwero.l'.0fb*.W bbea*d Iquks MOMThemed/his ixxahnkrtraignal en dM coroash C Deb cancellation caroxt tlprCtetm dthh cora'act C_motEa) sigr assn . (= oPtma urdt liwrahte. Oedt nb kwrrte nhd.taaAt,dsahlEr ttunn Check the Ihntrace dsdrrad: C Lge (Buyer C Co-Buyer C Bash C 1 ODbabiltY Aaidmt and asn,,,,Buyw C Co-Buyer C) Nana d Imurer tanr oBim Adder d deiWSOd irehrer, maximum amount d khsu ante hrhder Ms cohhoan k S N/ A , and the mount d insurance undo dhis and any eht contract of the Buyer under Seller's ris Polley. is limited b f MIA . The Initial .-I of credit i's N/A The mo ith, berea of credit Accident and health insons"is5 .Ia am 1, fix, w,hx mn lea as elimination or waking periods provided or the I and will be payable to =- urdesv brace by Uhe i«urance catmm?r, the 'll he Buyer Signauue )),tae ' aglk.deft..ykrl?r?irskhaNekt?ad.awnuyh C,amYoh l [tsYaa skive d D.t Nyna A t w r9a.e has pba You agree under seal b 0. sans and candtbns set tarts on both side ddb aamnn[I. Yw sryhed thb catwact on JUNE 27, 2008 20 _ of W all no6c a bbnb were completed 1. Do not sign this contract in blank NOTICE TO BUYER 2. You are entitled to an exact copy of the contract rose 5f?n. Keel it to protect our W tits Buyer ac6towledged receipt of a can PIetefi copy bf this ccd8 aR the ti of Shc: Buyer. ISFAO SeIWS ltepreerhbt 1 CaBuyer: ISFAU Eric: Co-sil- ISEAU The fdlowi w ' s;gni dls act W for the crtam d mirhg yw a sechr'ty instred in the vehicle.We can modify, change or vary the terms of the conrXt gntlwlrq bnhe wgwNrhma rd ronekale am guW e« Penn dthg« wlthdat np?Wap «warning the undersigned. eranbr faaanryry )honer MAD Grantor d5eaeirylnsnest (SEAL) I00? S?4SES AYE?TN VIl]ElA ATCNNONn, VA 73224 our Seer BtkamtrtltP SaT1tM YJt6acmdstt¢hate deYbs doe DNids%ossted,shkd set the-sfh rite OKI Sale C=W ad D'edwoe SitleamL SdkrS rIeFF H0?9'?kR Date: 6177/2009 eanniaSedafebaArik d'nrnoe,_niledriPlevpdh ddibdnmdtimr4a ice fraprhE«ethmxakb4uis (Seal) Seal) Co-Buyer .. ADDITIONAL TERMS AND CONDITIONS 1. AIIooBmdPar:Ita1WH Daily lr t/Can«Ratioedlmunna: We thallue4 W The written demand clearly deswibes ouch other pr it each d your nbndl paNneres Brat ICI pya:ry Ch IX fins you (M.e wrier Mn it. ABOmeys Fen, Court ad Otlkr CaBectien Caf::lo/ U conma if ref¢rrM for amen, second to any unpaid Finance Gu afd t?eaReL b reduce pincipI collKOon by us m an mom-y who is not our pladed employee, you Agree m PAY in any oil. order we wish. Interest will be comPYRd by applying the Annual reasonable ats-fa lees together with any covet and niter cdlopiat cods Y e W PA Pacenlage RyAW so the Unpaid balmo, d the Amount Fkpncd unit actuallypd inuerd. Your is not ly peyholiday must he received by us no later than 200 pm a a weelda 11. Right of Sebk R we Accelerate pa meet d the contraq we can also take an at? ove oorder ffices or such i? Addison ff se date, Your wynnm well amounts which you haww deposit wsth and apply them to pymeM of this co he made to us bar n any may be t I igrtaad b'y tractwany ot:erdebnwhichywowesalexceptlRAandKeogyo accouMsandpen, us M writing him time to time. Since Your Finance Charge accrues daly, B you are stn hxd9. FLOW, we may take Bess action without first giving you rhea. miduvhdy early in paying your irmulnenls, you less. paymerht wit be lee than 11. Aasigawt:ThbcWtmco isbei:gauigned by the Seller loSunTnw Bank. lithe scheduled. Ifyou are conislt ody lace, your Ixt pymeiR will be moue than xheb corona u turtM assigned by SunLust Bank, the assignee will have all of our rights lad. Any adjust mmnt in your final ppaayymet rewNirhO from payrmmerlB recehed w and powen. days din than she days you am scheduled b pay veil be ndkdd In a memm?m 15. each Buyer R?o?k d rror¢ Man We Buy.- Cosigr signsthis contract, coo m you by a ham m the due dated the final paymn . s sing Eh tin artbhm each h raporable Ion th eaiM balance dire crdh sale. due. Any mk tad a cancellation d arty imumce applicable m this contra4 a 14. Cmeaak Pima Casemkta [Nri d Debt: A OF YOUR COMNUNICA- AM -able gems, Mdudin g try appfic" neEeu of Finance Ch.", Al wbe TIONS TO SUHTRUST BANKCONCERNING WSPUTFA DEBTS, INCLUDING AN treated x a partial prepayment. INSTRUMENT TENDERED AS FULL SATISFACTION CAF THIS CONTRACT, 2. AdaYkrW Charges: SHOULD BE.SENY ro: Sun"" Bank, Attn: Loan Servicing DepL, P.O. Boa 651 60, W We China if your payment is more than 10 days lift, you will he'changid,l% ? RkMtoME-VA23185eS760. dtheaobtmtdue. /5 E B P 7HK CONTRACT CONTAINS.THE ENTIRE (b) Rethaerd Orafu If you have made a payment by check and your check is di.- AGil EATEN TFl SELLER AND THE BUYER, AND ANY NOT HE SUP- h"nered, you will coy us a fee In the highest Amami alkwaed by law. PLEMENTED OR MODIFIED ORALLY. BUT ONLY BY A WRITTEN INSTRUMENT (a Oeferab: N you wish to defies ere or moth f.yourar-thlY asd!wer WRY EXECUTED BY ALL PARTIES. pewit you in do so, we will.. inform you d." appli -ableake r, ( Uwe d your» '16. Widens ash faksmiphrp You waive any right a demand for pay- or notice zu-. d nohluir" upEn YourdelaulL U we ado d the'lime for payment d any imo& I A5 (d) Pebanne Ooge'd PaynAm DiaDamall:Youask ns-b'pnmanmW a'mog as mot, a waswiin 11 . w, we art tad rMsed bdo so M the Wbre. .=a your pay"mm due date, and we pemsk such a change, you will he chand lax d 1T. 4danoalion AUTHORIZE SUNTRUST BANKTO DISCLOSE ANY $25.00. INFORMATION IN RELATING TO THIS LOAN ACCOUNT (INCLUDING (e) Eausdig By, Due Date of a!a rrma: If you afk to In extend the due dare of a INFORMATION RECEIVED FROM THIRD PERSONS) TO ANY OF SUNTRUST pnicular paynomL and we permit you b der so, you will pay us a fee in Be highest BANK'S SUBSIDIARIES, AFFILIATES AND ASSIGNS AND TO ANY POTENTIAL aaibxedbyIa... _ ASSIGNEE, TRANSFEREE %P ARTICIPANT IN THE CREDIT 70 WHICH THIS (0 PnluYmetc h+uiryh lbu will not have to pay a penalty if you pry of the mount LOAN AOCOLINT APPLIETHE EVENT YOU'DO NOT WANT US.TO SHARE owed udn tlM contract cityy. CERTAIN INFORMATION WITH OUR AFEIUATES (OTHER THAN TRANSACTION- (gl Delashk YMe,s: Upon ddahlL including Wor failure to pay upon goal mauiq; AL OR EXPERIENTIAL INFORMATION), YOU MUST WRITE US AT SUNTRUST we, a our opi"n and without prior mice to you, may dl permiltd uMkr applka- BANK, ATTN: AFFILIATE SHARING, RIC 9292, PO .'BOX 26260, RIC7IMOND VA iii. lawl inuease.the APR by up W d. Peent (6%), umil g0 days ager such deGuh 23260-6264. PLEASE INCLUDE YOUR NAMF ACCAUNT NUMBER AND iiRIAL n rd. SECURITY NUMBER $0 THAT WE MAY PROCESS YOUR REQUEST. 3: lids d Lor(Acae4n4m and DafaulU You wit pa«us au arrbusls owed ceder IL Gom"ft Law: This contract is gwnned by the Internal Paws d the this mmtrad eveniftle vehicle isdama}d decru/ed miWhg.Madela=4% CtxmonweaRh ofPennsylvmlaad br Bm l_ofheUnadSUtes,Bthelawsgov- we haw the dghm at our option and whiluxa givirp you plor notitt or anaa" do not albw all al the owns set forth herein, the terms that are require tha you pay Irmmdia* the full amoum dirt wu owe undo this contract. not will be void. The not of this contract will still be edomeable. A default occurs if la) you do not male a may've together with your fate cfu gi 17. P. fdkmvitg prevision is applicable on%B this amat is for she sale da used within 10 dayfeftertin date the sdmdul, Paymea is due, IN my d you am in or yehide:THE INfORANTION YOU SEE ON YyH WINDOW FORM FOR THIS VEHI- file for ccyyrtutvehddp, «an Inmcf-4 p icesdbhg (d Ay of you de, (d) - CLE IS PMT OF THIS CONTRACT. -INFORMATION ON 7HE WINDOW FORM anywchrror hnnent, levy or.gA dshosem is ksued)ji anydpu wmy prep OVERRIDES ANY CONTRARY PROVISIONS W THE CONTRACT OF SUE erty, asset w Income d any d you, Wtral wdh wry dyau Teri b Redam asry promise you 10. YOU UNDERSTAND 7INT7HESELLER IS NOTOFFFRINGANT WARRANTIES centre M din corer W a any when an A (0 arty d you it had or ' AND THAT THEIR ME NO N1R)ED WARRANTIES OPMERCHANTABLLDY, OR make a roaw ialmWepeseaalim ata the in ammeaion with this contract, or W FITNESS FOR A PARTICULAR PURPOSE, OR ANY OTHER WARRANTIES, EXPRESS ((the vehick 1.=.,d«, dsmbne as c,w. In value I-cl adb 75%d. OR IMPLIED BY SELLER, COVERING THE GOODS UNLESS THE SELLER EMENDS I, wholesalemarketwlueasu ed m the mop ymr NADA La. A WRITTEN WARRANTY OR SERVICE CONTRACT WITHIN 90 DAYS FROM THE or sm , plthlkaiw m be deatmhbed.b a. Yau agne,b to DATE OF THIS CONTRACT. M immpplIld waraay of merchantability generally Inspect ohevehiclemdemrmina in anent value amyskne. upwhnbrudA, notice _111mthe Goods aR Mmrthe anllri y pose forwNdm such Gaols aro gen 4. latent You am grdrhbng Ys a security inlermt in tloevehicle ad any lly tad. A wamnry d fitreu i« pandcolar purpose if a vmnnry Mat wry arise fan, equipmeead mpl coma proiMalkid I. Bm vehicle. The secudrr when the 5dkrhmroxonbknow thepw larpupou for which your quired the Interest also covers W -fiance premam burred to a W pnocerrh dairy I-,- Goods ash you rely the SZ; skill w A arrant b Qsh bhaWe goods. This mepdicinasmriaordebtrartallatlomm?tracumtlmvehiCIA (dproweds po Wort does not affeam waranBes oaverMg the Goods which may be pevided (arty Iwrsnce Policies w yin life a Itakh which are FinaKed M this cereract yh the mamhawer d Me Goods. This gram secues pyvmnrc d all aromas you - x a remdl d this c"ntrM tad 21. NOTICE: ANY HOLOE! OF THIS CONSUMOI CREDIT CONTRACT IS SUF any 0 amh4 rdnhewa,-ion«asaiyvnmtefil. Italbsecurefyour.0_ P_,A JBCT TO ALL CLAIMS AND DIFFIM WIOCH THE. DWOR COULD ASSERT es In this contract, AGAN6T THE SELLER Of DODOS ON SERVIC9 OBTAINED PURSUANT Hill&- S. harahp: Mu agree b keep she vehicle insured for in fun value against lass or TO 01 WITH 1HE PROOF IHOEOF. RECOVERY HIBIEUND@ BY THE damwith an Insurance Amy' of your choice. The deductible on such inms- DEBTOR S"AU NOT EXCEED AMOUNTS MID BY THE DERFOR HEREUNDER. _.% ll be m than SMA00. You will Iwm 5.7" IWk u bss Payee w the Pdky wII's the policy to w. You will pwmmly pr all instance BALLOON PAYMFM OPTION yank wAw duq Provide prod of Pay- upon mgwx, sMd daily ui g coven . age frgpes. K you do not comply with my of lea mo simneees we at our option Inkpws Paynma ConfAW: N r have clown tin balloon pay-ht option, the may, wMae waiving ourrigln b d«lam each normeopgtfancu a default under this. fdkawnR prorisism apply to Witt contras: oW r cL oWM Insurance (Including physical damage imstA ), ter ou. urddu. pmltbRetl W Law. You will be I " i of the type of mumce adydm 21 B+Bsom P. sat; Under thetwm.1 Ns Balloon Pryment Contract you are rhage you m e pay THE COST OF THE INSURANCE WE BUY FOR YOU MAY BE oiepay tins Trial d Payments in a gW rn ehly imWlmmmq but with HIGH ER THiAN THE COST OF INSURANCE YOU BUYFOR YOURSELF . You agree . satRarfwl pytrmm 7hae pymwt, am ikmud in Me Schedule m Mk b- a for try insdance'premium. pin interest w such pars urn'At the of bChown WOW hat d this cwtracc you my satisfy your originally MmW Nnoentbge Rate disclosed on the ford side anvil the Proniums and InNMR scheduled final prymat obligation fn one of rWays. FirB, you may Imke mid in full. The premiwm pWa any MeeNTt a our option; will. be wyabk w Lim RmA pay nem. Second, You may rdMa; the Berl pa vnm+tl x sel font hdmhad d « added in the mul oulstadhg balance of the debt secured I Mis amv below. TMtd, you cosy .0 the vehicle x set bins hebw. your meaning monthly paynmrl(s wiil be ir-sed to cover tlmo addF 23. Re&sarrong: Yau mayy ? over da'"dplnally scheduled final payrmm liana, =.,r kmw-=I by a may provide, at our epdw, that such unless you are in defauh urda thk co tma, You must wovideproof dmwrance munthe lean unpad balance of your debt or tie rep'r w aresplad bus Ixtohe de ?n«irg and sign a rdinnre cwtracL We may replxaarriwm value d Ilre vehicle. thin maY ufe de P..-& d try I-.. charge a higher tale d Meat dumg the .Marmomhle period if such an mom is ahrainmed by us w Mtit you to repair or m4lxa the vehicle, or if we eI- m do m, to pamtiosd by law. Hosveva, V- 1Ae gpayme in dm mlis e repay put all d debt, and you will sill he mpamthle m arW n 'nkg contractwill be the sense x M aact The term d dm rdinmd?{ w will be unpaid balance of the debL you Latginn to 0 all amounts paytbk UMR the insw• based w the Amount mBNKd, the nk ard MO amount clBen monthly PAY. one, including anY unnamed Prtmbms dgettgu the imww b make payment mot. ==IV rwme Mmu?t us, you mnTnbliH us in writing. E ttya dkedry b YM ad yoY M us your anm?y. at to octane anry drag n- dish 23, thenowe shouts be mce.W m later dun 30 days Doamrhetms for i rtlher Mmar c Yau will gangly and defies to prior to dmrad pp?t due claw. . . such ash ad fadmr documenn as we may require W so ish or msintan 24. Sale a Sm mah You may sell de vehicle to us for an M- Al equm the fee qty Inaesr in tie vehicle, IN b correct any errors or anksiora in this can oripnalH scheduled Rrul payment, but oay if you art not fn deladt trier Mis trap, or (c) m help m meal the'whicle after mpomar.. SunTrat b outhomed to contract. Bella the saleanpyyouw ma Wpathey a a $300.OD dhwstdw ke ash pmvidk event daipal amt or minim in k constrict and all der papers eaeartrd, proof dw youbayecad with mm lachames maimenanoe schedule ad endo d, w asaigned Mmnneaknwith Be contract. You heels Tint nexyour mymdl woilmn. You mw abo pay se any exiew Mkageshiige,ak %with ::='"I do atever we may deers necasarv 0, pkL- o cactiwn a tins cop of try exux wee ash tor, x sn lards bebw. You m5 days um Wu dm vehunterest M Yen Mthkk and =7=4 n: *,; k to e place des V& by dfar pactskn fy u d gran o 1 the cl the 7. lHe re a to I NA n vehicle. . you 4piad Upon T adx: Anal pymem due dale. ARn the impeavm, it pas decide b .1 dm vehicle b With h rekmhce to ou W will ImeP R in Goad c«daiw ad newi h) A you naR give the vehicle to a no taco than she !:grime n due data. N will no* a knnadisely if it n lost, sblen, demmyed, or sAsurtially tpnvyled W that dr you mat rib sign ad deliver all papers hhaakr awrmrdtip will allow us b impet h a any-oartaNerime, Idlwill notpwdt it tote u01. dtlmvelack to us, AM the kuwdim it wu decide not to sell the vehicle to L Nepoaamlon And Sale of Vehkft d === ise a ou pion refs wnhact. lathe sek m m rsccurs w arty rink niter Mm tie wfginalH schert yaclaUddsedghmandbmdieswnderis U= ukd? Ipaymmtduedate the ens mikaga doge will be fgudw am Commercial Code or odes aodkable law ad all dghn provided in co_. this ran bads. mcludbtg'wiB_ Ikngalion de dglB b bkepwa? d tins wltek widmul your 26. bes Ww and T-% you are responsible ter AIL repairs to the vehicle sha pemraionad wiflbd givingyou rWceor Q1^ wa Wicial haring. You aaho- we ddw(i) flue exult of ease" war Adupm«(IO 1rad to ramm the vehk rize a m rata your lawiulIV win or wfthpa a court ader f« the ele b proper operating condition. Such replan 6miude, but are not limed to, of a hg powercon of dm vehkk. Aker repaasYw, we have dm ride m shit dm Mae nave y m: vehicle at pehRc auetlon «h"15 vam saleb reduce the amourd owed b a by y"u. b IU cameo any macMmcal mall-ions lemon dose that are not the real, d the event d sale we wiN xons6le notice of the time ad ace neglect «na -li; - dple.Bftvehcleisrid.Y seiL if sale Proceeds are snug, I (b) replan any dm not pan of a matcMng w of f«« any tire which has less to pay all amount awedunderder rmtrat (including any tan which we incur for than IM Inch of whaming tread; ad Insurance, reposaessiprh, smrage, «Ale of the vehkkt You will still be respwsibk Ira nwiry, re?Nlace « mrmw all pped, afted « min f« the Wlerme owed uses agnad m by. in writing. ad we alb have a right b mvchd boat comb, pint er whI===!A ll dmtd, umchd, aW in a defieW-y against you r« the balance whicfi h eve cod. recd, piped, broker «mh'amn{ trim and grillwM; !=; dnd, plied if we sake paseuim d Brc vehkk tenon d yam ddaulL y mays with our or Medan ldna' all faulty winrdosv meduMsms; all all broken appmal, regain of the vchide by payf all due wrnemt, our burned out I WO; all bkdor rip; can, bums or woin'aex; ad all damage P=o" wipwxnt whithsvwklbec and wilaw«co suehirdwarceisaceullyMface.NyouhavenamadeBm-Wnd lomiapec- n(thedMttlr. wrc ud ng possession, mpYmg, anclamig the vehicle which ebanh rf ed by law. rreetpdro. . vehkk uhdu Pargnph 14, you wIB ewe the asgnukd cap d ssmh U disagree with the eamaed cops of rep.1% You may have the you may resistant de vehicle al any time up m 15 days afar we mail yaua Noticed rtpaln made at your eapmse priormYav irkddm vehiclemus. mw =As my W. rime bd"re vw se0 or co xtm roil the whkla 11m 17. Odrnela: Vou am mpared be kdnal law b pmpdY ceaH' the Wme than 1155 ?wimpsee p tit veaCO"clenaemsm defau` lorgar th whiles etl? you sellttb us 11 dead resarwyinvehice?v?led I "- due asasion g repair• back Mt lly sdiedukd (urn d this comma you mustamidk Vi %and bid tie vehirde. ly mpalr a e e. 9. Other A'"pely Taken: We maytake poeegiw d am' popery not bbied to our lehesf which k In w, a agxhd p Be vehicle a time time we sake pis 1g, Mhedamemm you agree m hhdpmiffvv and am Anignee against km or dam =so the whlle. =,' fosfle pnopMy unka: age ad to hold a hamkss hart any ardall loss «damage to Anon or Property. (d You fin denomd in But we than such niter propA , and « exparC caned by dm vehicle, or by the use of or operation of the vehicle We riche o?oind nib us by ceniRd mail within 5 days aAer we take P-- maym6arxMhoaenn gpka yaa Mnad Legal repese"uUvea,U any paid Mis property. and snrmaamlaudmbaunenbhcca6k, tits will tact ream ash der Pan uersme . DEALER'S ASSIGNMENT Aai'maa: For vale renewed Mb'Seller'('Dealse) h p*by elh, asdgm, ad'I d- b SunTrw Bank, as succafow and awigra (15unTrusl'), ail of is nd?L dole ,.,At iMeml w thk Credit Sale Catract and Dtscl"pee Submt (•caMncYl ad M the colWknl d-,* .d in rise contract, with lull Power b ad in Be na me d dm Dealer « SonTmc. ash labrranhliec To inhdhtce SwTwl m acczpl ref amignmett Deter repr - ad warm. hhs, (1) all diKlahaes requlyd by law were properly made ,0 &ryer baba dhe oaaau wan I2) riser dpWwe deadr Buyer h pA lee, ad the cordfad vex s aerme, ypmd M Um Dakrf p (3) leap axh Buyef n a 18 yearsoMl alb the best d Dealdf each 8uVn had iull laid cwacny a coMrad, W Daakr had d1 b the vehicledexnbed in rte comet ( the'vehick'1 At dm rime d sae fine nice mY Litass, D) a1 nequi d instum ee docs-9.11- will be ddhxad m Buyer within the firm mwird by levy (6) the doweawant neceiwd by Dealer is eaacdyy , shown in the cor'aaa ad, Was than for approved mmufalueh rehae, m pan of the dowpaymnp has ben *_ad by Dealer so Buyee 0) the live head by tle coition t has ham racedd n mquked by suer law govnnhR doe vehicle, (B) m tMhea of Dealer's kmwkdge, no Buyer hxavn vidad my laws ga+ ¢miw rg l'puor «amWa. PJ1 b she best d DealaYS k.owledgm ail flnarckl idammon wpamd by each Buy, is acetone ad mmpkee. (10) Me contact h Wily nth old a adsm. Each d the begdng relossm awnsad wmeies is -M" W S-1ney, aciepbtae of this aaiganm4 and Dealer agrees m indw ly SunTrust AM Mel r Hshaded b. from all IiabffrtRdamages, hates ad .9- (Including hus 1*1. Adi fiscal, sustained by masw of my nasanaadon or wAAry w bin above prwirB b ba untrue, inaccu or misladi?. NBYhan nm:2N?!1, «rnianow D D M apa nnanpr ala'a a611gaam under Be faegoinn?? i daraarv poisig peaky tp«dicaliy apses Iha a rePreee a m d coma, ,7Dealer dull pimply and ns=== danwnd pay SunRustMaliont)r bll amoup of tins wpM balance of 1M'fwl d Paymentn• stand I. the cemxL mgder wgh my ad al by $ mine Dealer Agseesnerh Deaf, apex tlut in Wntlmr liability to SwTwt dull be Pavxrhmd by .9 provisions of anry Dealer Agreenea between Dealer And Suolruo. tf the above reprm¢mai,u ad wamda asbun and Dealds liability with respect to the contract mail be widrwt Rana union adifferent provision is nude in wining beareen SunTnm ad tins Dena. EXHIBIT "B" r.? rya Y?J . 02-11-'10 17;14 FROM- T-248 P001/001 F-029 Extension of Payment Agreement 069 0000443SaZO (0 The undersigned, jo n y and severally (if more than one signer below), are indebted to SunTrust bank, ("SunTrust") as evidenced by an instrument dated- . as may have been amended or rescheduled from time to time. Together with all other agreements or security doett tents a ecut d in connections with that indebtedness, ("the Loan"), which Loan has been assigned the account number lportowtm request that SunTrust change the payment schtdule for borrowers Loan. All terms and conditions of IN Loan not inconsistent herewith shall remain in fill force and tffeet. This Agreement is an extension only and not a novation. To the extent that any provision of this Agreement conflicts with any term or condition of the Loan, the provisions orthis Agreement will supersede and control. The validity, priority, and enforceability of the Loan will not be impaired by this agreement. Borrowers acknowledge, affirm and agree that (1) there are no claims, setoffs, defenses, or rights to claims, setoff, or defenses to payment of the Loan, (2) SunTrusl is not in breach of the Loan in any manner whatsoever, and (3) although Sun'rrust may have accepted late payments in the past, it will no longer accept late payments. Borrowers authorize SunTrust to modify all automatic payment or debit schedules and pay rents amounts, if applicable, to conform to the terms of this Agreement. As further con: ideration for this Agreement. Borrowers may be required to pay SunTrust a processing fee, which is a charge for SunTrust's mtpenses in rescheduling the loan payments and is not a penalty. Borrowers acknowledge receiving a copy ofthe agreement and acknowledge that they are entering into this agreement freely and willingly. Any insurance policy, debt cancellation agreement, or other service contract financed with the Loan may not continue into or be effective during any period beyond the original maturity date of the Loan. (See your insurance policy, service contract, or other doourncn(ation for coverage information.) Normal finance chargts, including interest, will continue to accrue in accordance with the original terms and conditions of the Loan document. Entering into this Agreement may affect the payoffamount of the Loan. The processing fee will not reduce your loan balance. Upon receipt of this signed agreement and a processing fee of so , the payment under the Loan will be modified us fellows: • The Paymetn(s) being deferred: • The Loan maturity date is extended to: L O • The next payment on the Loan is- due on: Man 1.i Agreement void If not received by ! 2119/2010 - - - Please return the entire form to the following address: Sufi trust Bank Attp.: General Support - RV W-7952 Post 00-1ce Box 85052 Richmond. VA 23285-5052 Muse Complete Fully the Following Information BORROWERS INFORMATON: Printed Name: Co-Maker Name: Resident Address: Co-Maker Address: City, St, 'Lip Code 't City, St, Zip Code: Reason for extension: Customer Slgnatu naer d)date Co-Maker Signature and Date SunTrust Bank \ Agent; 0'i? k 4tJt1 tj1?? Approved by.?• ` Date. d 16 1'itlc: ' Revised 02"10r2010 PLEASE IRGETVR E TIRE FORM . . EXHIBIT "C" SunTrust Bank MC CSRVW 7951 PO BOX 85052 Richmond, VA 23285 (866) 717-0734 M 0 N no Q to GO SuNTRusr Mae Cha Ryan 1210 Musket Ln Mechanicsburg, PA 17050-2095 Re: NOTICE OF REPOSSESSION AND PLAN TO SELL PROPERTY AT PRIVATE SALE SunTrust Loan No.: 443 XXXXXXXXXXXXX4986-1 Collateral Description: 2006 CADILLAC ESCALADE-V8 IGYEK63N36R159328 Storage Address: C & S Towing & Recovery 454 N Constitution Ave New Freedom, PA 17349 Dear Mae Cha Ryan: SunTrust Bank has taken possession of the Collateral described above because you broke your promises in our agreement under the loan identified above (the "Loan"). SunTrust Bank intends to sell the Collateral at a private sale sometime on or after May 8, 2010. A sale could include a lease or license. The money that we get from the sale (after paying our costs) will reduce the amount you owe under the Loan. If we get more money than you owe, you will get the extra money, unless we must pay it to someone else. If we get less money than you owe, you will still owe us the difference between the total amount due under the Loan and the amount generated by the sale (the deficiency). You may not be liable for the deficiency if this debt is discharged in bankruptcy or you are protected by the automatic stay. However, if your bankruptcy case is dismissed or you are denied a discharge of this debt, you may remain liable for the deficiency. We will provide you with an explanation of how the proceeds of the sale are applied to your loan upon sale of the Collateral. The amount due under the Loan is itemized below: Via First Class Mail & Certified Mail Return Receipt Requested April 23, 2010 Unpaid Principal Balance $28,665.69 Interest $659.34 Late Charges $38.37 Repossession Expenses $425.00 TOTAL $29,788.40 Interest will continue to accrue at the daily rate of $7.49. Storage fees will also accrue at a daily rate of $35.00. You may also be responsible for additional repossession expenses allowed by state law that are incurred after the date of this notice. To learn the exact amount you must pay, call us at 866-717-0734. You can get the Collateral back at any time before we sell it by paying the full amount you owe (not just the past due payments) including our repossession expenses. If you want to get the Collateral 10090-116100037.4.370372 111111111111 IN IIII 1111111111111111111111111111111 oil 3 111111111111 Ell 111111111 IIII 11111 1111111111 IIIII 111111111111111IN 05900004435234986 CCLT back, send payment of the amount specified in the form of a money order, cashier's check or other certified funds to the undersigned at the address given below. To learn the exact amount you must pay, call us at 866-717-0734. If you want us to provide you with a written explanation of how we calculated the amount that you owe us, you may call or write us at the phone number or address below: 866-717-0734 SunTrust Bank - Asset Disposition MC: CSRVW 7951 P.O. Box 85052 Richmond, VA 23285 Any personal items left in the repossessed Collateral will be held for 30 days from the date of this letter. You may reclaim the personal items within the 30 day time period. Thereafter, the personal items may be disposed of in the same manner as the repossessed Collateral. If you need more information about the sale, or if you want to claim any personal items described above, please contact the undersigned at phone number or address given above. We are sending notification to the other people listed below who have an interest in the Collateral or who owe money under the Loan (if applicable). Sincerely, Mxhll.Sha4haty Mitzi Shashaty Assistant Vice President 866-717-0734 Additional Parties Receiving Notice (if any): Letter: NOS PAPR; 10090 This communication is an attempt to collect a debt and any information you provide, whether written or verbal, will be used for that purpose. However, if your debt is discharged in bankruptcy or you are protected by the automatic stay in a bankruptcy proceeding, SunTrust recognizes that you may not be liable for this debt and this letter is not an attempt to collect a debt but is being sent for notice purposes only. Notice: The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided the applicant has the capacity to enter into a binding contract); because all or part of the applicant's income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The Federal Agency that administers compliance with this law concerning SunTrust Bank is the Federal Reserve Bank of Atlanta, Any questions concerning this creditor should be directed to the Federal Reserve Consumer Help Center, P.O. Box 1200, Minneapolis, MN 55480, toll-free number: (888) 851-1920, fax number: (877) 888-2520, TDD number: (877) 766-8533. Q MM SunTrust Bank is an Equal Housing Lender. Member FDIC. SunTrust is a federally registered service mark of SunTrust Banks, Inc. EXHIBIT "D" Sun7rust Bank Recovery Department P.O. Box 85041 Richmond, VA 23265-5041 (800) 211-9625 SunflRusT- Mae Cha Ryan 1210 Musket Ln Mechanicsburg, PA 17050-2095 Via First Class Mail & Certified Mail Return Receipt Requested March 19, 2011 EXPLANATION OF CALCULATION OF DEFICIENCY OR (SURPLUS) SunTrust Loan No: Collateral Description: Date of Sale: Deficiency Balance or (SURPLUS): Dear Mae Cha Ryan: XXXXXXXXXXXXX4986 2006 CADILLAC ESCALADE-V8 1GYEK63N36R159328 June 9, 2010 $13,010.54 As you were previously advised, SunTrust Bank repossessed the Collateral described above because you broke your promises in our agreement under the loan identified above (the "Loan"). The Collateral was sold on the above referenced date. The proceeds of the sale have been applied to the Loan as of the date of sale and are itemized below: Aggregate Amount of Obligation as of June 9, 2010 $29,677.17 LESS PROCEEDS FROM SALE ($17,500.00) TOTAL OUTSTANDING BALANCE $12,177.17 PLUS Repossession Expenses $795.00 (Which may include known expenses of retaking, holding, preparing for sale, processing, and disposing of Collateral to the extent permitted by law) PLUS Accumulated Fees and Costs $.00 (Which may include NSF fees, collection fees and attorney fees to the extent permitted by law) PLUS Late Charges $38.37 LESS Miscellaneous Rebates & Credits ($.00) (Which include known rebates of interest and credit service charges) DEFICIENCY OR (SURPLUS) on June 9, 2010 $13,010.54 The money we got from the sale (after paying our costs) has reduced the amount you owe under the Loan. If we got more money than you owe (surplus), that amount is enclosed. However, if the loan and its collateral were affected by a bankruptcy, the funds have been sent to the trustee. If we got less money than you owe, you will still owe us the deficiency, which is the difference between the total amount due under the Loan and the amount generated by the sale unless your personal liability for the loan has been 10028-080110028-58402266 11111oil IN IIIIIIIHill Hill 11111111IN III IN 1111111111111IN IIII111IIIIIN IIIIIII11111111111111IIIIII 05900004435234986 CPRE extinguished or limited by bankruptcy. For each day that the deficiency remains unpaid (if any), interest will continue to accrue at the contract rate of interest at 53.13 per day and will affect the amount of the deficiency. You may not be liable for the deficiency if this debt is discharged in bankruptcy. We will not sue for any deficiency if you are protected by the automatic stay. However, if your bankruptcy case is dismissed or you are denied a discharge of this debt, you may remain liable for the deficiency. You may have purchased other coverage which may entitle you to a refund of some portion of the original amount paid for this coverage. For example, you may have purchased a service contract or credit insurance products from the dealer who sold you your car. (Note: Whether or not you purchased any such additional coverage and the cost of same can be determined on the face of your loan contract.) Any refunds due to you for this type of coverage may be used to pay part or all of a deficiency. If there is a deficiency and you do not pay it, SunTrust may retain the services of an attorney to file suit and may be successful in obtaining judgment against you and any others who may be liable for payment of the Loan. You may be obligated to pay for the attorneys' fees and costs incurred by SunTrust in collecting the deficiency, and such fees and costs may affect the amount of the deficiency. Future debits, credits, charges (including additional credit service charges or interest), rebates, and expenses may affect the amount of the surplus or deficiency. If you have any questions about this transaction or you wish to make arrangements to pay the deficiency (if any), you may call or write us at the phone number or address below. SunTrust Bank - Recovery Department P.O. Box 85041 Richmond, VA 23285-5041 800-211-9625 Thank you for your prompt attention to this matter Sincerely, S. waUa nk S. Williams Assistant Vice President 866-717-0734 Additional Parties Receiving Notice (if any): Leiter: DEFBAL; 10028 THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION YOU PROVIDE, WHETHER WRITTEN OR VERBAL, WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOUR DEBT IS DISCHARGED IN BANKRUPTCY OR YOU ARE PROTECTED BY THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, SUNTRUST RECOGNIZES THAT YOU MAY NOT BE LIABLE FOR THIS DEBT AND THIS LETTER IS NOT AN ATTEMPT TO COLLECT A DEBT BUT IS BEING SENT FOR NOTICE PURPOSES ONLY. Notice: The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided that the applicant has the capacity to enter into a binding contract), because all or part of the applicant's income derives from any public assistance program, or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The federal agency that administers compliance with this law conceming this creditor is the Federal Reserve Bank of Atlanta. Any questions concerning this creditor should be directed to the Federal Reserve Consumer Help Center, P.O. Box 1200, Minneapolis, MN 55480, toll-free number: (888)851-1920, fax number: (877)888-2520, TDD number: (877)766-8533. a MA SunTrust Bank is an Equal Housing Lender. Member FDIC. SunTrust is a federally registered service mark of SunTrust Banks, Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Z;?X'Vt V at L 1 1 +p l ir+ n l' 1 2: ( e E ? 1 n. i _ S (L kNIA Suntrust Bank Case Number vs. Mae Cha Ryan 2012-1715 SHERIFF'S RETURN OF SERVICE 03/24/2012 12:18 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on March 24, 2012 at 1218 hours, he served a true copy of the within Complaint and Notic pon the within named defendant, to wit: Mae Cha Ryan, by making known unto herself personally, at 1 Musket Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents d t e s me time handing to her personally the said true and correct copy of the same. ('/' i j RISON, DEPUTY SHERIFF COST: $38.00 March 27, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF r ,n ...?. a l.. s, 3.`'U i1L't?J 261112 M Y ' U113ERLAND CUR T y PENNSYLVANIA Jay C. Scheinfield, Esquire Atty. I.D. No. 23880 8234 West Chester Pike Upper Darby, PA 19082 (610) 853-0300 SUNTRUST BANK 1030 Wilmer Avenue Richmond, VA 23227 Plaintiff VS. MAE CHA RYAN 1210 Musket Lane Mechanicsburg, PA 17050 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW NO. 12-1715 Civil PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF ANSWER, ASSESSMENT OF DAMAGES AND VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment by default for want of an answer in favor of Plaintiff and against the above- named MAE CHA RYAN and assess as follows: Principal $11,960.69 Interest @$3.12 per diem from 6/10/10 to 4/27/12 2,147.63 Total $14,108.32 Understanding that false statement herein made are subject to penalty under 18 Pa. C.S. A 'lip. GL C?? ? ? ?f Lo ?- a, u _?°'? Section 4904 relating to unsworn falsification to authority, I verify that: 1. The above are the precise last-known addresses of the judgment debtor(s) and creditor. 2. The annexed notice(s) of intention to file this Praecipe was/were mailed to all parties against whom judgment is to be entered and to her record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this Praecipe. 3. To the best of my personal knowledge and belief, the occupation of Defendant(s) is civilian; is not in the Military Service of the United States, nor any State or Territory thereof or its Allies as defined in the Service Members Civil Relief Act of 2003 and the amendments thereto, is over 18 years of age; and has civilian occupation(s). ?--) C/ Esquire JUDGMENT BY DEFAULT ENTERED AND DAMAG AS SE ABOVE: NOTICE EN ER R.CIV. . Jay C. Scheinfield, Esquire Attorney I.D. #23880 8234 West Chester Pike Upper Darby, PA 19082 (610) 853-0300 SUNTRUST BANK 1030 Wilmer Avenue Richmond, VA 23227 Plaintiff COPY Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA : CIVIL ACTION - LAW vs. MAE CHA RYAN 1210 Musket Lane Mechanicsburg, PA 17050 Defendant (s) TO: MAE CHA RYAN 1210 Musket Lane Mechanicsburg, PA 17050 DATE: APRIL 16, 2012 NO. 12-1715 Civil 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 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 NOTICE TO A 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 Jay C. Wield, Esquire A y for Plaintiff TI-m FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR DEBT COLLECTION PURPOSES. Jay C. Scheinfield, Esquire Atty. I.D.#23880 8234 West Chester Pike Upper Darby, PA 19082 (610) 853-0300 SUNTRUST BANK 1030 Wilmer Avenue Richmond, VA 23227 Plaintiff vs. MAE CHA RYAN 1210 Musket Lane Mechanicsburg, PA 17050 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA : CIVIL ACTION - LAW : NO. 12-1715 Civil CERTIFICATION OF ADDRESS I hereby certify that the precise address of the Plaintiff is 1030 Wilmer Avenue, Richmond, VA 23227; and the precise address of the Defendant, to the best of my knowledge, information and belief is: MAE CHA RYAN 1210 Musket Lane Mechanicsburg, PA 17050 Date: ?l ay cheinfield, Esquire ` orney for Plaintiff (RULE OF CIVIL PROCEDURE NO. 236) - REVISED SUNTRUST BANK 1030 Wilmer Avenue Richmond, VA 23227 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW vs. MAE CHA RYAN 1210 Musket Lane Mechanicsburg, PA 17050 Defendant TO: MAE CHA RYAN 1210 Musket Lane Mechanicsburg, PA 17050 NO. 12-1715 Civil NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. THONOTARY If you have any questions concerning the above, please contact: Jay C. Scheinfield, Esquire 8234 West Chester Pike Upper Darby, PA 19082 (610) 853-0300 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR DEBT COLLECTION PURPOSES