HomeMy WebLinkAbout12-6512IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST NATIONAL BANK OF CIVIL DIVISION
PENNSYLVAN@
NO.: _ f~l ~l
PL~intlff, ~ p2 ~QS/a~
vs.
TYPE OF PLEADING
JEFFREY S. WEARY,
TIMOTHY M. ROWE, CIVIL ACTION -COMPLAINT
FRED A. WEARY, I[ and IN BREACH OF CONTRACT
SUSAN A. WEARY.
Defendants.
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1.. .I,:~ lf~U~ i
FILED ON BEHALF OF:
First National Bank of Pennsylvania,lPlaintiff
To: DF:ErvllAnTis~ COUNSEL, OF RECORD FOR THIS
YOU ARE HEREBY NOTIFIED "f0 PLEAD TO THE PARTY.
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FKOM SERV[CE EREO DEFAULT JUDGMENT SCOtt A. DletteTlCk, ESgUlre
M.4Y BIi ENTER AINS c Pa. LD. #55650; Sad@sdc',.com
~ Kimberly A. Bonner, Esquire
~ Pa. LD. #89705; kab@jsdc.com
A'TTOR _ ~~OR PLAINTIFF
I HEREBY CERTIPY'I'IiA"F THE ADDRESS
oFTHE PLAIrdT~f~F Is: JAMES, SMITH, DIETTERICK &
CONNELLY, LLP
4140 E. State Street
Hermitage, PA 16148
AND THE DEFENDANT(S): P.O. BOX 6SO
10 Sgrignoli Lane Hershey, PA 17033
Enola, PA 17025 ~ ^
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ArroRNEV FOR ~r~FF (717) 533-3280; (717) 533-2795 (Fax
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IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~,,~' I692 ET
SEQ. (19"17), DEFENDANT(S) MAY DISPUTE THE VALIDITY O:F THE DEBT OR ANY
PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30)
DAYS OF RECEIPT OF THIS PLEADING, COUNSEI, FOR PLAII~TTIFF WILL C)BTAIN
AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF';
OTHERWISE, THE -DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF
REQUESTED WITHIN THIRTY (30) DAYS OF RECI?IPT OF THL'~ PLEADING. COUNSEL
FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS CsF THE
ORIGINAL: CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30)
DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING Y OU TO
COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES 'THAT YOUR ANSWER
TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS,
Y'OU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST
WILL BF; MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF
THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF
YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF 'CHF,
ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON
YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE: OUR.
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DI3BT UNTIL
WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN
ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS
SUIT.
IF YOU HAVE FILI?D BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN
ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO F,NFORCE A LIEN ON REAL
ESTATE.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST NATIONAL BANK OF CIVIL DIVISION
PENNSYLVANIA,
NO.:
Plaintiff,
vs.
JEFFREY" S. WEARY,
TIMOTHY M. ROWE,
FRED A. WEARY, I[ and
SUSAN A. WEARY.
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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 v~rriting 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 maybe entered against you b y the court
without fiarther 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.
YOL! SHOULD TAI<:E THIS PAPER TO YOUR LAWYER A'T ONCE. IF YOIJ SHOULD
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.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST NATIONAL BANK. OF CIVIL DNISION
PENNSYLVANIA,
NO..
Plaintiff,
vs.
JEFFREY S. WEARY,
TIMOTHY M. ROWS,
FRED A. WEARY, II and
SUSAN A. WEARY,
Defendants.
AVISO
LISTED HA SIDO DEMONDADO/.A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los
proximos veinte (20) Bias despues de la notifacacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comperencencia escrita y redicanco ~~n la Courte
por escrito sus defen:>as de, y objecciones a, los demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda. o cualquier
otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero O propieded a otros derechos
importances para usted.
LISTED DEBE LLEVAR ESTE DOCUMENTO A SU .~BAGADO IMMEDIATAME;NTE. SI
LISTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A LrNO, LLAM1=? A VAYA A
LA SIGUEINTE OFICINA PARR AVERIGUAR DONDE PUEDE ENCONTRAR
ASISTENCIA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (717) 249-3166
(800) 990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST NATIONAL I3ANK OF CNIL DNISION
PENNSYLVANIA,
NO.:
Pl ~aintiff,
vs.
JEFFREY S. WEARY,
TIMOTHY M. ROWE,
FRED A. WEARY, II and
SUSAN A. WEARY.,
Defendants.
CIVIL ACTION -COMPLAINT IN BREACH OF CONTRACT
And now comes First National Bank of Pennsylvania, Plaintiff, by its attorneys. James,
Smith, Dietterick & Connelly LLP, and files this Complaint in Breach of Contract as follows:
The Plaintiff is First National Bank of Pennsylvania, which has its principal place
of business 4140 E. State Street, Hermitage, Pennsylvania 16148.
2. The Defendants, Jeffrey S. Weary, Timothy M. Rowe, Fred A. Weary, [I and
Susan A. Weary, are adult individuals whose last known address is 10 Sgrignoli Latae, Enola,
Pennsylvania 17025.
3. On or about September 5, 2007, Defendants executed a Promissory Note ("Note")
in favor of Plaintiff in the original principal amount of $115,000.00. A true and correct copy of
said Note is marked Exhibit "A", attached hereto and made a part hereof.
4. Under the terms of the aforesaid Note, Plaintiff is entitled to accelerate payment
of the principal balance, accrued and unpaid interest and all other sums due and owing
under the terms of the Note upon the occurrence of an event of defau}.t, including brat not limited
to, the failure to pay monthly installments of principal and interest when due.
5. The aforesaid Note has not been released, transferred or assigned by Plaintiff.
6. Defendants have breached their duty imposed by the aforesaid Note and are in
default under the ternis of the said Note for, inter alia, failing to make; monthly installments of
principal and interest when due.
7. Any and all conditions precedent to payment to Plaintiff have been satisfied.
8. Notwithstanding Plaintiffs demands for payment, Defendants' obligations under
the terms of the aforementioned Note remain unsatisfied.
9. The amount due and owing Plaintiff by Defendants is as follows:
Principal $ 95,870.56
Interest through 10-5-2012 $ ?,049.52
Late Charges $ 2,470.65
Satisfaction Fee $ 40.50
Simple Insurance through 10-5-2012 $ 273.52
Previous Fees & Costs $ 100.00
Attorneys' Fee & Costs $ 2,500.00
TOTAL $ 103,304.75
plus interest on the principal sum ($95,870.56) from October 5, 2012., at the contracaual rate of
$18. ~6 per diem, plus additional late charges, and costs.
WHEREFORE, Plaintiff demands judgment in its favor and against Defendants for the
total amount due of $103,304.75, with interest on the principal sum ($95,870.56) from October
5, 2012, at the rate of $18.36 per diem, plus additional late charges, attorneys' fees and costs.
JAMES, s~~rL~, L~~"filK & cowwELLY 1_LP
Scott'A. Dietterick, Esquire
PA LD. # 55650; sad@jsdc.com
Kimberly A. Bonner, Esquire
PA I.D #89705; kab@jsdc.com
Attorneys for Plaintiff
P.O. Box 650
Hershey, PA 17033
(717) 533-3280
(717) 533-2795 (Fax)
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBIT "A"
N~I~I~
PROMISSORY NOTE
References in the boxes above are for Lender's use only and do not limit the applicability of this document to any particular loan or item.
Any item above containing ""~"' has been omitted clue to text lenoth limitations.
Borrower: JEFFREY S WEARY; TIMOTHY M ROWE; FRED A Lender: First National Bank of Pennsylvania
WEARY, II; and SUSAN A WEARY Harrisburg
320 NORTH 67TH STREET HERMITAGE, PA
HARRISBURG, PA 1,7111
Principal Amount: $115,000.00 Interest Rate: 6.990% Date of Note: September 5, 2007
PROMISE TO PAY. I ("Borrower") jointly and severalty promise to pay to First National Bank of Pennsylvania ("Lender"), or order, in lawful
money of the United States of America, the principal amount of One Hundred Fifteen Thousand 8 00/100 Dollars ($115,000.00), together with
interest at the rate of 6.990% per annum on the unpaid principal balance from September 5, 2007, until paid in full. The interest rate may
change under the terms and conditinns of the "INTEREST AFTER DEFAULT" section.
PAYMENT. I will pay this loan in 180 payments of $1,176.56 each payment. My first payment i:s due October 5, 2007, and all subsequent
aayments are due on the same day of each month after that. My final payment will be due on September 5, 2022, a.^.d wi!; be for all principal
and all accrued interest and all credit insurance premiums, not yet paid. Payments include principal .and interest and credit insurance premiums.
Unless otherwise agreed or required by applicable taw, payments will be applied first to any unpaid credit insurance premiums, accrued to the
date of receipt of payment; then to any accrued unpaid interest; then to principal; then to any unpaid collection costs; and then to any late
charges. Interest on this Note is computed on a 365/365 simple interest basis; that is, by applying the ratio of the annual interest rate over the
number of days in a year, multiplied by the outstanding principal balance, multiplied by the actual number of days the principal balance is
outstanding. I will pay Lender at Lender's address shown above or at such other place as Lender may designate in writing.
LATE CHARGE. If a payment is 15 days or more late, I will be charged 1 D.000% of the regularly scheduled payment. or $20.00, whichever is
greater.
INTEREST AFTER DEFAULT. Upon eiefault, including failure to pay upon final maturity, the total sum due under this Note will continue to accrue
interest at the interest rate under this Note. If judgment is entered in connection wi~,th this Note. interest will continue Uo accrue after the date of
judgment at the rate in effect at the time judgment is entered.
DEFAULT. I will be in default under this Note if any of the following happen:
Payment Default. I fail to make any payment when due under this Note.
Break Other Promises. I break any promise made to Lender or fail to perforrrr promptly at the time and strictly in the manner provided in
this Note or in any agreement related to this Note, or in any other agreement or loan I have with Lender.
Default in Favor of Third Parties. I or any Grantor defaults under any loan, extension of credit, security agreement, purchase or sales
agreement, or any other agreement, in favor of any other creditor or person that may materially affect any of my property or my ability to
repay this Note or perform my obligations under this Note or any of the related documents.
False Statements. Any represeantation or statement made or fumished to Lender by me or on my behalf under /:his Note or the related
documents is false or misleading in any material respect, either now or at the time made or furnished.
Death or Insolvency. Any Borrower dies or becomes insolvent; a receiver is appointed for any part of my property; I make an assignment
for the benefit cif creditors; or any proceeding is commenced either by me or against me under any bankruptcy or insolvency laws.
However, my death will not be a,n event of default if as a result of the death the; Indebtedness is fully covered by credit life insurance.
Taking of the Property. Any creditor or governmental agency tries to take any of the property or any other of my property in which Lender
has a lien. This includes taking of, garnishing of or lerying on my accounts with Lender. However, if I dispute ira good faith whether the
claim on which the taking of the property is based is valid or reasonable, and if' I give Lender written notice of the claim and furnish Lender
with monies or a surety bond satisfactory to Lender to satisfy the claim, then this default provision will not apply.
Defective Collateralization. This Note or any of the related documents ceases to be in full force and effect (including failure of any collateral
document to create a valid and perfected security interest or lien) at any time and for any reason.
Collateral Damage or Loss. Arty collateral securing this Note is lost, stolen, substantially damaged or destroyed and the loss, theft,
substantial damage or destructin,, is not covered by insurance.
Events Affecting Guarantor. Any of the preceding events occurs with respect 'to any guarantor, endorser, surety, or accommodation party
of any of the indebtedness or .any guarantor, endorser, surety, or accommodation party dies or becomes incompetent, or revokes or
disputes the validity of, or liability under, any guaranty of the indebtedness evidenced by this Note. fn the event of a death, Lender, at its
option, may, but shall not be required to, permit the guarantor's estate to assunne unconditionally the obligations arising under the guaranty
in a manner satisfactory to Lender, and, in doing so, cure any Event of Default.
Insecurity. Lender in good faith trelieves itself insecure.
Cure Provisions. If any default, other than a default in payment is curable and if I have not been given a notice of a breach of the same
provision of this Note within the preceding twelve (1c) months, it may be cured if I, after receiving written notice from Lender demanding
cure of such default: (1) cure the default within fifteen (15) days; or (2) if the cure requires more than fifteen i;15} days, immediately
initiate steps which Lender deems in Lender's sole discretion to be sufficient to cure the default and thereafter continue and complete all
reasonable and necessary steps sufficient to produce compliance as soon as reasonably practical.
LENDER'S RIGHTS. Upon default, Lender may, after giving such notices as required by applicable: law, declare the entire unpaid principal
balance under this Note and all accrued unpaid interest immediately due, and then I will pay that amount.
ATTORNEYS' FEES; EXPENSES. Lender may hire or pay someone else to help collect this Note if I do not pay. I will pay Lender that amount.
This includes, subject to any limits under applicable law, Lender's reasonable attorneys' fees and Lender's legal expenses, whether or not there
PROMISSORY NOTE
(Continued)
Page 2
is a lawsuit, including reasonable attorneys' fees, expenses for bankruptcy proceedings (including efforts to modify or vacate any automatic stay
or injunction). and appeals. If not prohibited by applicable law, I also will pay any court costs, in addition to all other sums provided by law.
RIGHT OF SETOFF. To the extent permitted by applicable law, Lender reserves a right of setoff in all my accounts with Lender (whether
checking, savings, or some other account). This includes all accounts I hold jointly with someone else and all accounts I may open in the future.
However, this doers not include any IRA or Keogh accounts, or any trust accounts for which setoff would be prohibited by law. I authorize
Lender, to the extent permitted by applicable law, to charge or setoff all sums owing on the indebtedness against any and all such accounts,
and, at Lender's option, to admini;;tratively freeze all such accounts to allow Lender to protect Lender's charge and setoff rights provided in this
paragraph.
COLLATERAL. i acknowledge this Note is secured by the following collateral described in the security instrument listed herein: a Mortgage
dated September 5, 2007, to Lender on real property located in CUMBERLAND County, Commonwealth of Pennsylvania.
ARBITRATION. I a.nd Lender agree that all disputes, claims and controversies between us whether individual, joint, or class in nature, arising
from this Note or atherwise, including without limitation contract and tort disputes, shall be arbitrated pursuant to the Rules of the American
Arbitration Association in Pffect at fhg timr thn gl~im it filnrl u~an rn~,~oet of eitlhnr parr,. Na acr ~.. ~e4n ..r .cienr.~a ai o •+•, °,eCL'ri^„
....,r.,_., ..ny prope,.~ ,y
this Note shall constitute a waiver of this arbitration agreement or be prohibited try this arbitration .agreement. This includes; without limitation;
obtaining injunctive relief or a temporary restraining order; invoking a power of sale under any deed of trust or mortgage; obtaining a writ of
attachment or impasition of a receiver; or exercising any rights relating to personal property, including taking or disposing of such property with
or without judicial process pursuant to Article 9 of the Uniform Commercial Code. Any disputes, claims, or controversies concerning the
lawfulness or reasonableness of any act, or exercise of any right, concerning any property securing this Note, including any claim to rescind,
reform, or otherwise modify any agreement relating to the property securing this Note, shall also be arbitrated, provided however that no
arbitrator shall have the right or the power to enjoin or restrain any act of any party. Judgment upon any award rendered by any arbitrator may
be entered in any court having jurisdiction. Nothing in this Note shall preclude any party from seeking equitable relief from a court of competent
jurisdiction. The statute of limitations; estoppel, waiver, !aches, and similar doctrines which would otherwise be applicable in an actian brought
by a party shall be applicable in any arbitration proceeding, and the commencement of an arbitration proceeding shall be deemed the
commencement of an action for these purposes. The Federal Arbitration Act shall apply to the construction, interpretation, and enforcement of
this arbitration provision.
EARLY TERMINATION FEE. An Early Termination Fee of $350.00 may be charged if this loan is pair! off prior to the third anniversary date of the
note. The original principal amount of the note must be 550,000 or greater for this fee to be applicable.
SUCCESSOR INTERESTS. The terms of this Note shall be binding upon me, and upon my heirs, personal representatives, successors and
assigns, and shall inure to the benefit of Lender and its successors and assigns.
NOTIFY US OF INACCURATE INFORMATION WE REPORT TO CONSUMER REPORTING AGENCIES. Please notify us if we report any inaccurate
information about your account(s) to a consumer reporting agency. Your written notice describing the specific inaccuracy(ies) should be sent to
us at the following address: First National Bank of Pennsylvania Attn: Privacy Department 4140 Eas': State Street Hermitage, PA 1 61 48-348 7.
GENERAL PROVISIONS. If any part of this Note cannot be enforced, this fact will not affect the rest of the Note. Lender may delay or forgo
enforcing any of its rights or remedies under this Note without losing them. I and any other person who signs, guarantees or endorses this
Note, to the extent allowed by law, waive presentment, demand for payment, and notice of dishonor. Upon any change in the terms of this
Note, and unless otherwise expressly stated in writing, no party who signs this PJote, whether as maker, guarantor, ,accommodation maker or
endorser, shall be released from liability. All such parties agree that Lender may renew or extend (repeatedly and for any length of time) this
loan or release any party or guarantor or collateral; or impair, fail to realize upon or perfect Lender's security interest in the collateral. All such
parties also agree that Lender may rnodify this loan without the consent of or notice to anyone other than the party with whom the modification
is made. The obligations under this Note are joint and several. This means that the words "I", "me", and "my" rnean each and all of the
persons signing below.
PRIOR TO SIGNING THIS NOTE, I, AND EACH OF US, READ AND UNDERSTOOD ALL THE PROVISIONS OF THIS NOTE AND THE NOTICE TO
COSIGNER SET FORTH BELOW. I, AND EACH OF US, AGREE TO THE TERMS OF THE NOTE.
I ACKNOWLEDGE RECEIPT OF A COMPLETED COPY OF THIS PROMISSORY NOTE:.
THIS NOTE IS GIVEN UNDER SEAL AND IT IS INTENDED THAT THIS NOTE 18. AND SHALL CCINSTITUTE AND HAVE THE EFFECT OF A
SEALED INSTRUM1rNT ACCORDING TO LAW.
BORROWER
~~
~ ~ '
X ., G !GG`=' (Seal;
JEFPR~S ARY ~~
X (Seal}
F D A WEARY, I-~~~ c~
,~..
NOTICE TO COSIGNER
You are being asked to guarantee this debt. Think carefully before you do. If the borrower doesn't pay the debt, you will have to. Be sure you
can afford to pay if you have to, and that you want to accept this responsibility.
You may have to pay up to the full amount of the debt if the borrower does not pay. You may also have to pay late fees or collection costs,
which increase this arnount.
The Lender can collect this debt from you without first trying to collect from the borrower. The Leander can use the same collection methods
against you that can be used against the borrower, such as suing you, garnishing your wages, etc. If this debt is ever in default, that fact may
become a part of YOUR credit record.
This notice is not the contract that makes you liable for the debt.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
FIRST NATIONAL BANK OF
PENNSYLVANIA,
Plaintiff:
vs.
JEFFREY S. WEARY,
TIMOTI-IY M. RO~WB,
FRED .A. WEARY, II and
SUSAN A. WEARY,
Defendants.
CIVIL DIVISION
NO.:
VERIFICATION
I. Elizabeth B. Sant, Vice President of First National Bank of Pennsylvania, depose and
say subject to the penalties of 18 Pa.C.S.A., sec.4904 relatixlg to nns~rorn falsification to
authorities that the facts set forth in the foregoing pleading are true ar~d correct to tfie best of my
information, knowledge and belief.
Date:~j~` I ~ ~-~
~ r
Elizabeth .Sant
Vice President of First National Bank ~~f
Pennsylvania
SHERIFF'S OFFICE OF CUMBERLAND COUNT(
onny R Anderson
Jd
Sheriff -~ "~ ~ r ~
s. _ ~ r; ~ r!t! P'~~~~~ „'
;r
Jody SSmith -~ ~
Chief Deputy 7~' ~ ~ ~`~`~ -~ ~~ ~~:
Richard W Stewart ~~~r*~~~t~~~~?t~~`~3 ..._ ~1 .
Solicitor ~FPv~'S"I.~'A~!(A ~
First National Bank of Pennsylvania Case Number
vs.
Jeffrey S. Weary (et al.j 2012-6512
SHERIFF'S RETURN OF SERVICE
10/25!2012 06:39 PM -Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint &
Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to
wit Fred A. Weary, II at 10 Sgrignoli Lane, East Pennsboro Township, Enola PA 17025.
,- ;'
GUTSHA PUTY
10/25/2012 06:39 PM -Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint &
Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Susan A. Weary at 10 Sgrignoli Lane, East Pennsboro Township, Enol~ PA 17025
~4lDJ- UTSHAL .DEPUTY
10/25/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he rrrade a diligent search
and inquiry for the within named defendant to wit: Timothy M. Rowe, but was unable to locate him in his
bailiwick. He therefore returns the within Complaint and Notice as not served at 10 Sgrignoli Lane, Enola,
Pennsylvania 17025. Deputies were advised by defendant's parents that defendant currently resides at
320 N. 67th Street, Harrisburg, Pennsylvania 17101 anti his place of employment is located 891
Eisenhower Boulevard, Harrisburg, Pennsylvania.
10/25/2012 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: Jeffrey S. Weary, but was unable to locate him in his
bailiwick. He therefore returns the within Complaint and Notice as not served at 10 Sgrignoli Lane, Enola,
Pennsylvania 17025. Deputies were advised by defendant's parents that defendant currently resides at
320 N. 67th Street, Harrisburg, Pennsylvania 17101 and his place of employment is located 891
Eisenhower Boulevard, Harrisburg, Pennsylvania.
SHERIFF COST $91.00
November 02. 2012
SO ANSWERS,
/~ - ,r
1/ ~ / ,.
RONNY R ANDERSON. SHERIFF