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Home My WebLink About13-3468 ,Lloyd S. Markind, Esquire (113#52507) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616 -8710 FILE NO.: FT 114572 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY, a I p Delaware limited liability Company I No. 13 - 3468 cl Vl ITl'M I Plaintiff(s) I Term I C n V. I CIVIL ACTION a cn i— _ r SCOTT R YOUNG AND DONNA L REED -YOUNG c_C z. � CD11_ Defendants) I _ . PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please issue judgment in the above matter against SCOTT R YOUNG AND DONNA L REED - YOUNG , Defendant(s) and in favor of FORD MOTOR CREDIT COMPANY, a Delaware limited liability Company, Plaintiff, in the amount of $7,706.69 plus interest from JULY 18, 2011. Date: June 5, 2013 Lloyd S. Markind, Esquire (ID #52507) 102 Browning Ln, Bldg B, Ste 1 s 33. 5 o Pb Am/ Cherry Hill NJ 08003 856/616 -8710 31n The Court of Common VYeaz of 33aupbin Countp, 3pennopibania Ford Motor Credit Company, A Delaware Limited Liability Company No. 2010 -CV- 11443 -CV VS. Scott R. Young Donna L. Reed -Young CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of Plaintiff, Ford Motor Credit Company, A Delaware Limited Liability Company and against Defendant, Donna L. Reed -Young on July 18, 2011 in said case in the amount of $7706.69 plus costs. In Te .5timoup Wbereof, I have hereunto set my hand and affixed the k i ourt, on Monday, May 13, 2013. Prothonotary By: Deputy Date: 5/13/2013 Dauphin County User: AWELCOMER Time: 09:26 AM Complete Case History Page 1 of 3 Case: 2010 -CV- 11443 -CV Ford Motor Credit Company vs. Scott R Young, etal. Filed: 9/2/2010 Subtype: Civil Physical File: Y Appealed: N Comment: Status History Pending 9/2/2010 Pending / Judgment 7/18/2011 Judge History Date Judge Reason for Removal 9/2/2010 No Judge, Current Payments Receipt Date Type Amount Law Offices of Andrew Sklar 295314 5/13/2013 Miscellaneous 26.25 Exemplified Record 26.25 _ Maurice & Needleman 256852 7/18/2011 Civil Filing 20.50 Needleman, Joann (attorney for 234580 9/2/2010 Civil Filing 145.50 Total 192.25 Miscellaneous Receipts Receipt Date 295314 5/13/2013 Exemplified Record 26.25 Sum: 26.25 Plaintiff Name: Ford Motor Credit Company SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys Needleman, Joann (No longer on case) Do Not Send Notices Sklar, Andrew (Primary attorney) Send Notices Defendant Name: Young, Scott R SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys Lieberman, Robert B (Primary attorney) Send Notices Date: 5/13/2013 Dauphin County User: AWELCOMER Time: 09:26 AM Complete Case History Page 2 of 3 Case: 2010 -CV- 11443 -CV Ford Motor Credit Company vs. Scott R Young, etal. Defendant Name: Reed Young, Donna L SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Register of Actions 9/2/2010 New Civil Case Filed This Date. No Judge, Plaintiff: Ford Motor Credit Company No Judge, Attorney of Record: Joann Needleman Filing: Complaint Paid by: Needleman, No Judge, Joann (attorney for Ford Motor Credit Company) Receipt number: 0234580 Dated: 9/2/2010 Amount: $145.50 (Check) For: Ford Motor Credit Company (plaintiff) ,6� AOPC MONTHLY CIVIL COURT No Judge, STATISTICAL REPORT DATA 0 Debt Collection: Other Complaint filed. 9/10/2010 Complaint: Sheriffs Return filed stating No Judge, service was completed. So answers J.R. ® r Lotwick, Sheriff. to Donna L Reed Young on 9/10/2010; Assigned to Dauphin Co Sheriffs Office. Service Fee of $87.00. - - 9/13/2010 Complaint: Sheriffs Return filed stating No Judge, service was completed. So answers J.R. Lotwick, Sheriff. to Scott R Young on 9/13/2010; Assigned to Dauphin Co Sheriffs Office. Service Fee of $0.00. Lebanon County Sheriffs Costs: $57.50 10/5/2010 Robert B. Lieberman, Esquire enters No Judge, appearance on behalf of defendant, Scott R. Young. See Praecipe, filed. 12/29/2010 The Verification attached to complaint is No Judge, hereby Substituted. See Praecipe, filed. 7/18/2011 Filing: Judgment Paid by: Maurice & No Judge, Needleman Receipt number: 0256852 Dated: 7/18/2011 Amount: $20.50 (Check) For: Ford Motor Credit Company (plaintiff) AOPC MONTHLY CIVIL COURT No Judge, STATISTICAL REPORT DATA; CIVIL ACTION Date: 5/13/2013 Dauphin County User: AWELCOMER Time: 09:26 AM Complete Case History Page 3 of 3 Case: 2010 -CV- 11443 -CV Ford Motor Credit Company vs. Scott R Young, etal. Register of Actions 7/18/2011 Default Judgment is entered in favor of No Judge, Plaintiff and against Defendant(s) DONNA L REED -YOUNG in the amounts as follows: Count I Principal per Workout Agreement: $4378.7 Less: Payments to date: ($1650.00) Interest from 03/18/2010 to 6/28/2011 @6 %: $494.22 Sub - Total: $3222.95 Count II Principal per Workout Agreement: $4694.0 Less Payments to date: ($450.00) Interest from 03/18/2010 to 6/28/2011 @ 6 %: $239.65 Sub - Total: $4483.74 TOTAL: $7706.69 for failure to answer Plaintiffs Complaint. See Praecipe & Notice filed. Copies of all documents mailed. 1/11/2013 Sklar — Markind by Andrew Sklar, Esq No Judge, substitutes appearance for that of Joann Needleman, Esq on behalf of Plaintiff: Ford Motor Credit Company 5/13/2013 Miscellaneous Payment: Exemplified No Judge, Record Paid by: Law Offices of Andrew Sklar Receipt number: 0295314 Dated: 5/13/2013 Amount: $26.25 (Check) Judgment Order date In Favor Of Disposition Judgment 07/18/2011 Plaintiff 07/18/2011 Open Default Comment: Count I: Sub - Total: $3222.95 Count II: Sub - Total: $4483.74 TOTAL: $7706.69 Plaintiff: Ford Motor Credit Company Defendant: Reed g, Donna L MAY 13 201 Yo hereby certify that the f eg ing is a, true a corr ct op of a igiVi filed. Prothonot ry/Clerk of C rts: . Ti's,• ,Lloyd S. Markind, Esquire (ID #52507) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616 -8710 FILE NO.: FT114572 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY, a Delaware limited liability Company I No. Plaintiff(s) I Term . I V. I CIVIL ACTION I SCOTT R YOUNG AND DONNA L REED -YOUNG I Defendant(s) I :4 I CERTIFICATION OF JUDGMENT /ADDRESSES Lloyd S. Markind, hereby certifies: 1. That he is the attorney for the Plaintiff in the above matter. 2. That the Defendant(s) is /are SCOTT R YOUNG AND DONNA L REED -YOUNG 3. That the last known address of the Defendant(s) is /are 5600 RIDGEVIEW DR HARRISBURG PA 17112 -2568. 4. The Plaintiff is PoRD MOTOR CREDIT COMPANY, a Delaware limited liability Company and their address is 1335 S. Clearview Avenue Mesa, AZ 85209. 5. That the foreign judgment entered by the Plaintiff, FORD MOTOR CREDIT COMPANY, a Delaware limited liability Company, and against the Defendant(s), SCOTT R YOUNG AND DONNA L REED -YOUNG , in the COURT OF COMMON PLEAS, DAUPHIN COUNTY, PENNSYLVANIA, in the sum of $7,706.69 is valid, enforceable and unsatisfied. k I hereby certify that' he above statements are true. I am aware if any of the above statements are willfully false, I am subject to punishment. Date: June 5, 2013 Lloyd S. Markind, Esquire i �( GYo c �. fila,`1 -ed / 0� C ^� c= ) ," MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff: BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center N i 1617 John F. Kennedy Blvd cn Philadelphia, PA 19103 co (215) 789 -7151 FORD MOTOR CREDIT COMPANY, A DAUPHIN COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. 2010 -CV- 11443 -CV V. SCOTT R YOUNG AND DONNA L REED -YOUNG Defendant(s) () Notice is hereby given that a judgment in the above - captioned matter has been entered against you in the amount of $7706.69 on 2 n 1l () A copy of all documents filed with the Prothon in support of the within judgment is enclosed. . Al Prdffionotary/Clelk If you have any questions regarding this matter, please contact the filing party: Name: Joann Needleman, Esquire Address: Suite 935, One Penn Center at Suburban Station 1617 J.F.K. Boulevard Philadelphia, PA 19103, Telephone No.: 215- 789 -7155 (This Notice is given in accordance with Pa.R.C.P. §236) 14A 1 1 [ �3 i'.hcreby certify that the fore goin si — c true and correct copy of the original Med. Prothon tary MAURICE & NEEDLEMAN, P.C. Attorneys for PlaintifF -, •�? BY: Joann Needleman, Esq. '.=' Identification No. 74276 935 One Penn Center ca 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789 -7151 co FORD MOTOR CREDIT COMPANY, A DAUPHIN COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. 2010 -CV -I 1443 -CV V. SCOTT R YOUNG AND DONNA L REED -YOUNG Defendant(s) PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION AND CONSENT TO THE PROTHONOTARY: Pursuant to the attached Workout Agreement for Payment and Consent to the Entry of Judgment, kindly enter Judgment in favor of Plaintiff, and against Defendant, DONNA L REED -YOUNG in the amount as follows: COUNT Principal per Workout Agreement $ 4378.73 Less: Payments to date ($1650.00) Interest from 03/18/2010 to 6/28/2011 @ 6 % $ 494.22 Sub -Total $ 3222.95 MAY 13 2013 I hereby certify that the foregoing i,, a true and correct copy of the original fled. Prathon,.tary COUNT II Principal per Workout Agreement $ 4694.09 Less: Payments to date ($ 450.00) Interest from 03/18/2010 to 6/28/2011 @ 6% $ 239.65 Sub -Total $ 4483.74 TOTAL 77U6•Gg MAURICE & NEEDLEMAN, P.C. BY: JO NEEDLEMAN, ESQ. Attorney for Plaintiff Date: June 28, 2011 i; MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd c� Philadelphia, PA 19103 (215) 789 -7151 - FORD MOTOR CREDIT COMPANY, A DAUPHIN COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. 2010 -CV- 11443 -CV V. SCOTT R YOUNG AND DONNA L REED -YOUNG Defendant(s) AFFIDAVIT OF CONSENT TO JUDGMENT STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that Defendant, DONNA L REED -YOUNG has entered into a Workout Agreement for Payment and Consents to the Entry of Judgment, a copy of which is attached hereto. MAURICE & NEEDLEMAN, P.C. BY: JO NEEDLEMAN, ESQ. Atto ey for Plaintiff SWORN TO ANSUBSCRIBED 4b kneme this ay 20 �� ' NOTARIAL SEAL RASHETTA ROBINSON lie Notary Public FPMIMY LADELPHIA CITY, PHILADELPHIA COUNTY Commission Expires Mar 23, 2015 i� MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff? r" BY: Joann Needleman, Esq. " c Identification No. 74276 ' 935 One Penn Center `' _' = co ; 1617 John F. Kennedy Blvd Philadelphia, PA 19103 :Y; (215) 789 -7151 cn ra FORD MOTOR CREDIT COMPANY, A DAUPHIN COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff . CASE NO. 2010 -CV- 11443 -CV V. SCOTT R YOUNG AND DONNA L REED -YOUNG Defendant(s AFFIDAVIT OF NON - MILITARY SERVICE STATE OF PENNSYLVANIA , SS. COUNTY OF PHILADELPHIA JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that she represents the Plaintiff in the above entitled case and that Defendant, DONNA L REED - YOUNG, is over 18 years of age; the occupation of Defendant is unknown and to the best of Plaintiffs knowledge, information and belief, Defendant is not in the military service of the United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. MAURICE & N DLEMAN, P.C. BY: JO NEEDLEMAN, ESQ. Attorney for Plaintiff SWORN TO ADP_ SUBSCRIBED bet a me this `j ay o , 200(. 7PHILAOCL RIAL SEAL ola ary otary Public TA R0BINSON Notary Public PHILADELPHIA COUNTY Expires Mar 23. 2015 ILI MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff;: BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center '=► N .t Ln 1617 John F. Kennedy Blvd s7 Philadelphia, PA 19103 (215) 789 -7151 FORD MOTOR CREDIT COMPANY, A DAUPHIN COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. 2010 -CV- 11443 -CV V. SCOTT R YOUNG AND DONNA L REED -YOUNG Defendant(s) CERTIFICATION OF ADDRESSES It is hereby certified that the parties have the following addresses: Plaintiff. FORD MOTOR CREDIT COMPANY P.O. BOX 6058 MESA, AZ. 85216 Defendant: DONNA L REED -YOUNG 4105 SPRING VALLEY ROAD - APT C3 HARRISBURG, PA 17109 MAURICE & NEEDLEMAN, P.C. BY: JOANfYNEEDLEMAN, ESQ. Atto y for Plaintiff Date: June 28, 2011- MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff BY: Joann Needleman, Esq. Identification No. 74276 ; , _T3 Charlene A. Taylor, Esq. Identification No. 203920 r 935 One Penn Center co 1617 John F. Kennedy Blvd Philadelphia, PA 19103 215 789 -7155 FORD MOTOR CREDIT COMPANY, A LEBANON COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. V. SCOTT R YOUNG DONNA L REED -YOUNG Defendant (s WORKOUT AGREEMENT FOR PAYMENT AND CONSENT TO THE ENTRY OF JUDGMENT THIS AGREEMENT is made between FORD MOTOR CREDIT COMPANY, a Delaware limited liability company c/o Maurice & Needleman, P.C. 1617 John F. Kennedy Boulevard, Suite 935, Philadelphia, Pennsylvania 19103, hereinafter called the "Plaintiff' and DONNA L REED - YOUNG of 4105 SPRING VALLEY ROAD, APT C3, HARRISBURG, PA 17109 hereinafter collectively called the "Defendant" WHEREFORE: 1. The Defendant acknowledges having executed to the Plaintiff a Retail Installment Contract ( "Note ") under the terms of which Defendant promised to make certain payments of principal and interest to the Plaintiff according to a schedule more specifically set forth in the terms of the Note. 2. The Defendant acknowledges having failed to pay interest and principal as required 1Z�2... by the terms of the Note and is in default of the Note. 3. The Defendant acknowledges that there is immediately due and owing from him to the Plaintiff under the Note $4378.73, consisting of principal, interest, and attorney's fees (hereinafter the "Amount Due ") and the Defendant acknowledges having no set -off, credit, or claim against the Amount Due. 4. The Defendant desires to satisfy the Amount Due and therefore makes the above representations to induce the Plaintiff to enter into the within agreement for the payment of the Amount Due. 5. NOW THEREFORE: For good and valuable consideration described below, the parties agree as follows: a. Plaintiff may enter judgment against Defendant for the amount due, less any payments made before the entry of judgment, and the Defendant consents to the entry thereof. b. The Defendant shall make payments of $100.00 a MONTH due 03/20/2010 and on the same day of each month thereafter until it is paid in full. C. As of the date that Defendant signs this Workout Agreement, interest on the Note and for all subsequent payments shall accrue at the rate of 6 %, including interest from the date of the entry of the judgment; d. All other terms of the Note, unless otherwise set forth herein will remain unchanged. e. All payments under this Agreement will be made by check payable to "Maurice & Needleman, P.C. FMC Attorney Trust Account" at 1617 John F. Kennedy Boulevard, 2 Suite 935, Philadelphia, Pennsylvania 19103. Please reference the file number 12772 on all Payments 6. During the term of this Agreement, the Plaintiff will forebear from enforcing its judgment for the collection of the Amount Due provided the Defendant is not in default of any of the terms or conditions of this Agreement and makes all payments timely. 7. The Defendant will deliver to the Plaintiff, with a signed copy of this Agreement, answers to the "Questionnaire" simultaneously supplied to the Defendant with this Agreement. 8. EVENTS OF DEFAULT The following shall constitute an Event of Default under this Agreement: a. The Defendant fails to pay, when due and payable, any scheduled payment as set forth in paragraph 5 b. above, and such scheduled payment remains unpaid for more than ten (10) days b. The Defendant fails to return the Questionnaire. 9. PLAINTIFF'S REMEDIES UPON DEFENDANTS' DEFAULT. In the event Defendant fails to cure any default of as described above, Plaintiff will be permitted to commence execution proceedings forthwith. 10. This Agreement does not alter, amend or modify the Defendant's obligations to the Plaintiff under the above Note, unless otherwise set forth herein. This Agreement does not alter, amend or modify the Defendant's obligations to the Plaintiff under any other document which is not named herein. 11. The Defendant acknowledges that as of the date of this Agreement he has no claim, 3 whether known or unknown, against the PlaintiffAND HEREBY WAIVES AND GIVES UP ANY AND ALL CLAIMS HE MAY HAVE AGAINST THE PLAINTIFF AS OF THE DATE OF THIS AGREEMENT, WHETHER KNOWN OR UNKNOWN. 12. THE UNDERSIGNEDACKNOWLEDGES HAVING READ THIS AGREEMENT, UNDERSTANDS IT, AGREES TO ITS TERMS AND HAS RECEIVED A COPY OF IT, WITHOUT CHARGE. Dated: �/�X /Y0 DONNA L REED -Y UNG Defendant B Dated: Charlene Taylor, Esq. Attorney for Ford Motor Credit Company 4 MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 203920 -- 935 One Perin Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 C :; CO 215 789 -7155 FORD MOTOR CREDIT COMPANY, A DAUPHIN COUNTY COURT OF DELAWARE LIMITED LIABILITY COMMON PLEAS COMPANY Plaintiff CASE NO. V. DONNA REED -YOUNG SCOTT R YOUNG Defendant(s) WORKOUT AGREEMENT FOR PAYMENT AND CONSENT TO THE ENTRY OF JUDGMENT THIS AGREEMENT is made between FORD MOTOR CREDIT COMPANY, a Delaware limited liability company c/o Maurice & Needleman, P.C. 1617 John F. Kennedy Boulevard, Suite 935, Philadelphia, Pennsylvania 19103, hereinafter called the "Plaintiff' and DONNA REED - YOUNG of 4105 SPRING VALLEY ROAD, APT C3, HARRISBURG, PA 17109 hereinafter collectively called the "Defendant" WHEREFORE: I . The Defendant acknowledges having executed to the Plaintiff a Retail Installment Contract ( "Note ") under the terms of which Defendant promised to make certain payments of principal and interest to the Plaintiff according to a schedule more specifically set forth in the terms of the Note. 2. The Defendant acknowledges having failed to pay interest and principal as required 147 7,3 e . by the terms of the Note and is in default of the Note. 3. The Defendant acknowledges that there is immediately due and owing from him to the Plaintiff under the Note $4694.09, consisting of principal, interest, and attorney's fees (hereinafter the "Amount Due ") and the Defendant acknowledges having no set -off, credit, or claim against the Amount Due. 4. The Defendant desires to satisfy the Amount Due and therefore makes the above representations to induce the Plaintiff to enter into the within agreement for the payment of the Amount Due. 5. NOW THEREFORE: For good and valuable consideration described below, the parties agree as follows: a. Plaintiff may enter judgment against Defendant for the amount due, less any payments made before the entry of judgment, and the Defendant consents to the entry thereof. b. The Defendant shall make payments of $100.00 a MONTH due 03/20/2010 and on the same day of each month thereafter until it is paid in full. C. As of the date that Defendant signs this Workout Agreement, interest on the Note and for all subsequent payments shall accrue at the rate of 6 %, including interest from the date of the entry of the judgment; d. All other terms of the Note, unless otherwise set forth herein will remain unchanged. e.. All payments under this Agreement will be made by check payable to "Maurice & Needleman, P.C. FMC Attorney Trust Account" at 1617 John F. Kennedy Boulevard, 2 ,. Suite 935, Philadelphia, Pennsylvania 19103. Please reference the file number 12773 on all Payments 6. During the term of this Agreement, the Plaintiff will forebear from enforcing its judgment for the collection of the Amount Due provided the Defendant is not in default of any of the terms or conditions of this Agreement and makes all payments timely. 7. The Defendant will deliver to the Plaintiff, with a signed copy of this Agreement, answers to the "Questionnaire" simultaneously supplied to the Defendant with this Agreement. 8. EVENTS OF DEFAULT The following shall constitute an Event of Default under this Agreement: a. The Defendant fails to pay, when due and payable, any scheduled payment as set forth in paragraph 5 b. above, and such scheduled payment remains unpaid for more than ten (10) days b. The Defendant fails to return the Questionnaire. 9. PLAINTIFF'S REMEDIES UPON DEFENDANTS' DEFAULT In the event Defendant fails to cure any default of as described above, Plaintiff will be permitted to commence execution proceedings forthwith. 10. This Agreement does not alter, amend or modify the Defendant's obligations to the Plaintiff under the above Note, unless otherwise set forth herein. This Agreement does not alter, amend or modify the Defendant's obligations to the Plaintiff under any other document which is not named herein. 11. The Defendant acknowledges that as of the date of this Agreement he has no claim, 3 i i whether known or unknown, against the Plaintiff AND HEREBY WAIVES AND GIVES UP ANY AND ALL CLAIMS HE MAY HAVE AGAINST THE PLAINTIFF AS OF THE DATE OF THIS AGREEMENT, WHETHER KNOWN OR UNKNOWN. 12. THE UNDERSIGNEDACKNOWLEDGES HAVING READ THIS AGREEMENT, UNDERSTANDS IT, AGREES TO ITS TERMS AND HAS RECEIVED A COPY OF IT, WITHOUT CHARGE. 0 44, 4 _ 1 Dated: 3I 1 �0 DONNA REEDJYO Defendant By: Dated: 6/-, -7/`/ C arlene Taylor, Esq. Attorney for Ford Motor Credit Company 4 Request for Military Status Department of Defense Manpower Data Center Jan-25 -2010 09:30:27 Military Status Report Pursuant to the Service Members Civil Relief Act Last I A Marne Tiirst/Nllddleegiu Date Au�tivEtDutyitus vEatydte. . ; . w 'r REED- DONNA Based on the information you have furnished the DMDC does not possess any YOUNG information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based: on the information that you provided, the above is the current status of :the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Health, and Coast Guard). d Mary M. Snavely -Dixon = ' C_ :.�%D C= <= Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209 -2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official :source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 -:et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940)..DMDC has issued hundreds of thousands of "does not possess any information indicating that the:individual-is currently on active duty" responses, and has experienced a small error rate. In the .event the individual referenced: above, or any family member, friend, or representative asserts in any manner that the individual is:on active duty; or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification• the person's status by contacting that person`s Service via the "defenselink.mil" URL http://www.defenselink-niiUfaq[2is/PC09SLDR.html If you have evidence the person is on active duty and you fail to .obtain this additional Service verification, punitive:provisions of . the SCRA may be invoked against you. See 50 USC App. §521(c). . If you obtain additional information about the person (e.g.,.:an.SSN, improved accuracy of:DOB, a'rriiddle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active dutyjf it was within the preceding 367 days. For historical information, please contact the Service SCRA points -of- contact. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for period of more than 30 consecutive days. In the case of a member of the National Guard; includes service under :.a call to active service authorized by the President or the Secretary of Defense for a,period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service https:// www. dmdc. osd.mil/appi /scra/popreporLdo[1 /25/2010 12:30:47 PMl r ' Request for Military Status or f e National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for .a.period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active: duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or:to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date. on Active Duty entry is important because ..a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights> guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on:a name and SSN:provided by the requester .Providing an. erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:UGAQ6N41L5 https: / /www.dmde.osd. mil /appj /scra/popreport.do[1 /25/2010 12:30:47 PM) ,Lloyd S. Markind, Esquire (ID#52507) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616 -8710 FILE NO.: FT114572 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY, a I Delaware limited liability Company I No. I Plaintiff(s) I Term I I V. I CIVIL ACTION . I SCOTT R YOUNG AND DONNA L REED -YOUNG 1 i Defendant(s) I I (Applicable to real estate and personal property) 236 NOTICE OF FILING JUDGMENT E () Notice is given that a judgment in the above captioned matter has been entered against you in the amount of $ `�' '7C , t'o9 on �� e , 20 (__j A copy of all documents filed with Jerk on i ort of the ithin judgment is /are enclosed. of urts ' othonotary Date: June 5, 2013 By: Deputy If you have any questions regarding this Notice, please contact the filing party: Lloyd S. Markind, Esquire (ID#52507) 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 1 856/61 6 -8710 (This Notice is given in accordance with Pa.R.C.P. No. 236) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY,a Delaware limited liability Company I No. 13-3468 1335 S. Clearview Avenue Mesa,AZ, 85209 Plaintiff(s) V. CIVIL ACTION SCOTT R YOUNG AND DONNA L REED-YOUNG I PRAECIPE FOR WRIT OF EXECUTION 5600 RIDGEVIEW DR I (Money Judgment) HARRISBURG PA 17112-2568 Defendant(s) 1 C= Z3 rn c— n M V. ,k I AMERICHOICE FEDERAL CREDIT CD UNION C. 715 WERTZVILLE RD C) ENOLA,PA 17025 C� CO Garnishee(s) TO THE PROTHONATORY: (1) Issue writ of execution in the above matter,directed to the Sheriff of CUMBERLAND County, against DONNA L REED-YOUNG ,defendant(s) (2) and against,'AMERICHOICE FEDERAL CREDIT UNION, 715 WERTZVILLE RD, ENOLA, PA 17025 garnishee. AMOUNT DUE $7,706.69 aQ,00 pt-A' INTEREST $894.25 33,5s 31D.5o CBF- o 66 from: July 18, 2011 $ 3q3.00 PO At PLUS COSTS Lloyd S. Markind,Esquire (ID #52507) Attorneys for Plaintiff 41as QUA Sklar- Markind "50 102 Browning Lane,Building B, Suite I Cherry Hill,New Jersey 08003 (856) 61678710 Dated: June 27, 2013 jqa= FILE NO.: FT1 14572 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-3468 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY,a Delaware limited liability Company, Plaintiff(s) From SCOTT R.YOUNG and DONNA L.REED-YOUNG,5600 Ridgeview Dr,Harrisburg,PA 17112-2568 (1) You are directed to levy upon the property of the defendant(s)and to sell (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: AMERICHOICE FCU,715 Wertzville Rd,Enola,PA 17025 and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and froin delivering any property of the defendant(s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due$7,706.69 Plaintiff Paid$ Interest from 7/18/11 -- $894.25 Attorney's Comm. % Law Library$.50 Attorney Paid$373.00 Due Prothonotary$2.25 Other Costs$ Date: 7/11/13 David D. Buell,Prothonotary Deputy REQUESTING PARTY: Name : LLOYDS.MARKIND,ESQUIRE Address: SKLAR-MARKIND 102 BROWNING LANE,BLDG B,SUITE I CHERRY HILL,NJ 08003 Attorney for:PLAINTIFF Telephone: 856-616-8710 Supreme Court ID No. 52507 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i !°1l Sheriff ;fiF` THE PROT I NO 1;µit 'f cr��r b4 ti:Arr�i��r'�� Jody S Smith i � .� . Chief Deputy AM 10 2 9 . r Richard W Stewart 'r 1. r CUMBERLAND COUN f Y' Solicitor 091C E OF THE SHERIFF PENNSYLVANIA Ford Motor Credit Company, LLC A Delaware Limited Liabilty Company Case Number vs. Scott R Young (et al.) 2013-3468 SHERIFF'S RETURN OF SERVICE 07/24/2013 01:44 PM-Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2013 at 1344 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Scott R. Young and Donna L. Reed-Young, in the hands, possession, or control of the within named garnishee, AmeriChoice Federal Credit Union, 715 Wertzville Road, Enola, Cumberland County, Pennsylvania, by handing to Mark Kresge, Member Services Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to him. The writ of execution and notice to defendants were mailed on July 25, 2013 to Scott R. Young at 600 Ridgeview Drive, Harrisburg, PA 17112-2568 and to Donna L. Reed-Young at 5600 Ridgeview Drive, Harrisburg, PA 17112-2568. Ayriwawiol AMA DA COBAUGH, DEPUT U SO ANSWERS, July 25, 2013 RONNY R ANDERSON, SHERIFF (0 CountySuito Sheriff,Teleosoft, ric. Lloyd S. Markind, Esquire (ID #52507) Jordan W. Felzer, Esquire (ID #38670) SKLAR—MARKIND 102 Browning Lane, Building B, Suite 1 Cherry Hill,New Jersey 08003 (856) 616-8710 Attorney for Plaintiff(s) Our File Number: FT114572 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY, a : No. 13-3468 Delaware limited liability Company Plaintiff TERM vs. CIVIL ACTION rr,as M_: SCOTT R YOUNG AND DONNA L CD REED-YOUNG -- C:) Defendant CD a AMERICHOICE FEDERAL CREDIT UNION - Garnishee(s) PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the attachment as to garnishee, AMERICHOICE FCU, in the above captioned action. Date: eilg�1 Lloyd S. Markind, Esquire (ID#52507) Jordan W. Felzer, Esquire (ID #38670) Attorneys for Plaintiff Sklar—Markind 102 Browning Lane, Bldg B, Suite 1 Cherry Hill,NJ 08003 (856) 616-8710 phone "q,,$°(� P (856) 616-8716 fax C /S'a_S713 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 01 C41 JP her( Jody S Smith Chief Deputy L 2� � Richard W Stewart 'UM P 4o D G H Solicitor ° = ENNSYE L Li PNOIJ Ford Motor Credit Company, LLC A Delaware Limited Liabilty Company Case Number vs. Scott R Young (et al.) 2013-3468 SHERIFF'S RETURN OF SERVICE 07/24/2013 01:44 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2013 at 1344 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Scott R. Young and Donna L. Reed-Young, in the hands, possession, or control of the within named garnishee, AmeriChoice Federal Credit Union, 715 Wertzville Road, Enola, Cumberland County, Pennsylvania, by handing to Mark Kresge, Member Services Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to him. The writ of execution and notice to defendants were mailed on July 25, 2013 to Scott R. Young at 600 Ridgeview Drive, Harrisburg, PA 17112-2568 and to Donna L. Reed-Young at 5600 Ridgeview Drive, Harrisburg, PA 17112-2568. 02/26/2014 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $110.80 SO ANSWERS, February 26, 2014 RONR ANDERSON, SHERIFF ,54D Atot L4 gS"/row 3 /93 r .a, E- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY, a Delaware limited liability Company 1335 S. Clearview Avenue Mesa, AZ, 85209 Plaintiff(s) v. SCOTT R YOUNG AND DONNA L REED -YOUNG 5600 RIDGEVIEW DR HARRISBURG PA 17112-2568 Defendant(s) v. MEMBERS FIRST FEDERAL CREDIT UNION 1711 SPRING RD CARLISLE, PA 17013 Garnishee(s) No. 13-3468 CIVIL ACTION PRAECIPE FOR WRIT OF EXECUTION (Money Judgment) Ci CD c TO THE PROTHONATORY: (1) Issue writ of execution in the above matter, directed to the Sheriff of CUMBERLAND County, against SCOTT R YOUNG AND DONNA L REED -YOUNG , defendant(s) (2) and against, MEMBERS FIRST FEDERAL CREDIT UNION, 1711 SPRING RD, CARLISLE, PA 17013 garnishee. Amount Due Post Judgment Costs Interest from: July 18, 2011 PLUS COSTS C7 } YA , cic)d a � •316, (10.gO`<<r 33.50 `1' a RSIL 4• 30 ated: Septem er 112, 2014 FILE NO.: FT114572 $7,706.69 $229.55 $1,441.16 Lloyd S.1',Tarkind, Esquire (ID #52507) Attorneys for Plaintiff Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 Cherry Hill, New Jersey 08003 A (856)616-8710 (Z#* 311(4)31 Olf e -Dgel THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net FORD MOTOR CREDIT COMPANY, a Delaware limited liability Company Vs. NO 13-3468 Civil Term CIVIL ACTION — LAW SCOTT R. YOUNG AND DONNA L. REED -YOUNG WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against SCOTT R. YOUNG AND DONNA L. REED -YOUNG, 5600 RIDGEVIEW DRIVE, HARRISBURG, PA 17112 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS FIRST FEDERAL CREDIT UNIONGARNISHEE(S), as garnishee, 1711 SPRING ROAD, CARLISLE, PA 17013 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as 1 determined by the executing officer, The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $7,706.69 Plaintiff Paid Interest FROM JULY 18, 2011 - $1,441.16 Law Library Attorney's Comm. % Due Prothonotary $2.25 0:.S Attorney Paid $522.30 Other Costs ati%..1 k. 0.0c44, 2.2?. A' Date: • 91aq/it( (Seal) In,,A4,111 David D. Buell, Prothonotary REQUESTING PARTY: Name : LLOYD S. MARKIND, ESQUIRE Address: MARKIND LAW GROUP, P.C. 102 BROWNING LANE, BUILDING B, SUITE 1 CHERRY HILL, NJ 08003 Attorney for: PLAINTIFF Telephone: 856-616-8710 Supreme Court ID No. 52507 MAJOR EXEMPTIONS 'UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FiLE0-0FF i.0 <«x�, at c urigt,tri>.. OF THE PROTHONOTARY 2014 OCT -t PH '2.51' Q,FFtCEOF THEW RIFF CUMBERLAND COUNTY PENNSYLVANIA Ford Motor Credit Company, LLC A Delaware Limited Liabilty Company vs. Scott R Young (et al.) Case Number 2013-3468 SHERIFF'S RETURN OF SERVICE 10/07/2014 01:23 PM - Jamie DiMartile, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Kimberly Whitaker, Branch Manager, personally six copies of interrogatories together with six true and attested copies of the Writ of Execution (three per defendant) and made the contents there of known to her. The writ of execution and notice to defendant was mailed on October 8, 2014 to Donna L. Reed -Young at 5600 Ridgeview Drive, Harrisburg, PA 17112-2568 and to Scott R. Young at 5600 Ridgeview Drive, Harrisburg, PA 17112-2568. E DIMARTILE, DEPUTY SO ANSWERS, October 08, 2014 RONNR ANDERSON, SHERIFF (c) CcuntySuite SSherit;, ieieosoft, inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-'LAW ° FORD MOTOR CREDIT COMPANY, a : No. 13-3468 Delaware limited liability Company RECEIVED Plaintiff VS. CIVIL ACTION OCT 0 8 2014 S G AND- Defendant R EIVED V. 2014 CD MEMBERS FIRST FEDERAL CREDIT UNION 1711 SPRING RD = CARLISLE, PA 17013 MMC=) r , rq -<> c. Garnishee( ) s c; -, -� -, v c�-E CD C aY1Sli INTERROGATORIES IN ATTACHMENT TO: MEMBERS FIRST FEDERAL CREDIT UNION , Garnishee: Youarerequired to-file answers to the following interrogatories within twenty(20)days after service upon you. Failure to do so may result in judgment against you. L : At the time you were served or at any subsequent time did you owe the defendants) any money or were you liable to him (her/them)on any negotiable or other written instrument, or did he (she/they)'claim that you owed him(her/them) any money or were liable to him (her/them) for any reason? 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession,custody or control of yourself and one or more persons any property of any nature owned solely or in part by the defendant? 3.. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which the defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had any interest? t_k) RECEIVE, OCT 0 8 2014 5. At any time before or after you were served did the defendants)transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration thereof? 6. At any time after you were served did you pay,transfer or deliver any money or property tot he defendant(s)or to any person or place pursuant to his(her/their) direction or otherwise discharge any claim of the defendant(s)against you? SCO 7. If you are a bank or other financial institution, at the time you were sewed or any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption, the amount of finds in each account, and the entity electronically depositing those funds on a recurring basis. \v C--) 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 41 Pa.C.S § 8123? If so, identify each account. �J 9. How much is the value of any property in your possession belonging to the defendant(s)? N\� Date: September 12, 2014 Lloyd S. Markind, Esquire(ID#52507) Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 Cherry Hill, NJ 08003 (856) 616-8710 FILE NO.: FT114572 Disclosure You are hereby advised, pursuant to the Fair Debt Collection Practices Act, that this firm is deemed to be a debt collector attempting to collect a debt and any information obtained will be used for that purpose. Lloyd S. Markind, Esquire (ID #52507) Markind Law Group, P.C. 102 Browning Lane, Building B, Suite 1 Cherry Hill, New Jersey 08003 (856) 616-8710 Attorney for Plaintiff(s) Our File Number: FT114572 r+n- • • ') U14,1 4o pi; k: (7: P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY, a Delaware limited liability Company Plaintiff vs. SCOTT R YOUNG AND DONNA L REED -YOUNG Defendant vs. MEMBERS FIRST FEDERAL CREDIT UNION Garnishee(s) : No. 13-3468 TERM : CIVIL ACTION PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the attachment as to garnishee, Members First FCU, in the above captioned action. Date: October 17, 2014 Lloyd S. Markind, Esquire (ID #52507) Attorneys for Plaintiff Markind Law Group, P.C. 102 Browning Lane, Bldg B, Suite 1 Cherry Hill, NJ 08003 (856) 616-8710 phone (856) 616-8716 fax eJ do -v$ aM59,56A I, (-(.49