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Home My WebLink About12-22312107422 THIS IS AN ARBITRATION MATTER. DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 America's First Federal Credit Union 1200 4th Ave North Birminham AL 35203 VS. ASSESSMENT OF COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. ?? C7 "31 David Mutchler 90 Garfield Drive Carlisle PA 17015 NOTICE rnrn -c ? "3> C-) A? tit °ca uo -n Ln Cn t: , or 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 JUDGEMENT 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 56-) 0?? eio3.?sp Ck? I(o&'o& 9 p wa?3C111 ? COMPLAINT IN CIVIL-ACTION 1. Plaintiff, America's First Federal Credit Union , is a business entity authorized to conduct business in the Commonwealth of Pennsylvania with its principal place of business at the above captioned address. 2. Defendant), David Mutchler is/are adult individual residing at the address above captioned. 3. Plaintiff and Defendant(s) entered into a closed end motor vehicle lease contract which required Defendant(s) to make monthly payments for the utilization of the vehicle. 4. Defendant(s), defaulted on the terms of the lease resulting in a total deficiency of $15,476.65. 5. Attached hereto and incorporated herein by reference as Exhibit "A" is a copy of the lease agreement and deficiency balance documentation. 7. Despite repeated demand Defendant(s) has/have refused, failed ans till refuses to tender payment on this outstanding obligation. 6. Defendant's last payment on account was made on 3/9/2010. WHEREFORE, plaintiff claims of the defendant(s) the sum of $15,476.65 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2107422 6097861-10 America's First Federal Credit Union David Mutchler 3500.8000 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements. vl. ?? xcr,? NAME EXHIBIT "A" 733 2107422 6097861-10 America's First Federal Credit Union David Mutchler 3500.8000 AFFIDAVIT I, 74 /YL?iC/?•? , being duly served sworn according to law, depose and say that. 1. I am the agent for the Plaintiff herein and I have custody and control of the files relating to this account; 2. I have knowledge of the facts and circumstances in connection with this case; 3. Plaintiff's files are maintained in the usual and ordinary course of business; 4. This action is based on a claim for breach of contract and that damages are sought as a direct result of said breach; 5. There is now due and owing from defendant to plaintiff, the amount of $14,501.21 plus interest of $950.81 at the rate of 6.2% less credits in the amount of $.00 totaling $15,452.02 as of March 20, 2012. 6. If called upon, affiant can testify at trial as to the facts pertaining to this matter. The above facts are true and correct to the best of my knowledge, information and belief. v AFFIANT Sworn to and Subscribed before me this D-day of 2012 Notary Public SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ;LED, -'JF'E1-, 2012 APR 20 AM 8: 45 CU RE SYCD COUNT, ANIA America's First Federal Credit Union vs. Case Number David Mutchler 2012-2231 SHERIFF'S RETURN OF SERVICE 04/18/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 18, 2012 at 1510 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: David Mutchler. After several attempts the Deputies were unable to find David Mutchler at his residence. Deputies were advised by a neighbor David Mutchler is a truck driver and rarely home. SHERIFF COST: $34.00 SO ANSWERS, April 18, 2012 RON R ANDERSON, SHERIFF 2107422 rrr3 r r GORDON & WEINBERG, P.C. ` =;7a�a 4 BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 LR, JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 America ' s First Federal Credit COURT OF COMMON PLEAS Union CUMBERLAND COUNTY VS . DOCKET NO. 2012-2231 Civil David Mutchler E u� 90 Garfield Drive -o�. �..�. Carlisle PA 17015 « = =� -� nn I° a cD °r-n PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Plaintiffs ' Complaint in Civil Action in the above-captioned matter for an additional thirty (30) days . GORDON & WEINBERG, P.C. BY: FREDERIC I INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff (s) ULI SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - FIr `FILED-OF -E Sheriff UF THE PROTHM-O' T Jody S Smith r", Chief Deputy 2013 JUN 26 PM 2: 1,2 Richard W Stewart CUMBERLAND MINTY Solicitor OF TKSKRIFF PENNSYLVANIA America's First Federal Credit Union Case Number vs. David Mutchler 2012-2231 I SHERIFF'S RETURN OF SERVICE 06/2112013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: David Mutchler, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint&Notice as"Not Served"at 90 Garfield Drive, South Middleton Township, Carlisle, PA 17015. Fifteen attempts at service were made but deputies were unable to make contact with anyone at this address before the Complaint and Notice expired. SHERIFF COST: $61.90 SO ANSWERS, June 24, 2013 RbNW R ANDERSON, SHERIFF (c)CourlftySuite Sheriff,Teleosoft,Inc.