Loading...
HomeMy WebLinkAbout13-6329 Supreme Couof P'.ennsylvan>ia Cour of,Co mon Pleas ForProtltonotaay use 01dy: r, lvl C et Docket No: CIT RFRT AN County The information collected on this form is used solely for court administration purposes. This form does not sra lemenl or replace die filing and service of leadings or other papers as req uired by 1mv or rules of court. Cornpiencement of Action: S Complaint 0 Writ of Sunirnons Petition 0 Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiffs Name: VNB LOAN SERVICES, INC. Lead. Defendant's Name:SCOTT DEANER, JR. and AMANDA ,r DEANER T Are money damages requested? I Yes [ N Dollar Amount Requested: thin arbitration limits (check one) Doutside arbitration limits 0 N Is this a C'la .v Action Suit? [3 Yes N No Is this an MDJAppeal? E] Yes 2 No A Name ofPlaintifT /Appellant's Attorney: Amato Keating and Lessa, P.C. 0 Check here if you have no attorney (are a Self - Represented (Pro Se] Litigant) Nature of the Case Place an ")C' to the left of the ONE case category that most acctrately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Collection: Credit Card Board of Assessment 0 Motor Vehicle M b Collection: Other Board of Elections 0 Nuisance Dept. of Transportation Premises Liability 8 Statutory Appeal: Other S E] Product Liability (does not include mass tort) [� Employment Dispute: E [] Slander/Libel /Defamation Discrimination C El Other: [ Employment Dispute: Other [ Zoning Board , 0 Other: I [ Other: O MASS TORT [] Asbestos N Tobacco Toxic Tort - DES Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS [] Toxic Waste �] El Ejectment Other Ejectment [] Common Camon Law /Statutory Arbitration [] Eminent Domain/Condemnation 0 Declaratory Judgment Ground Rent Mandamus Landlord/Tenant Dispute 8 Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial Quo Warranto Dental E] Partition 0 Replevin Legal [] Quiet Title Other: Medical Other: Other Professional: Updated 111/2011 COURT OF COMMON PLEAS COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VNB LOAN SERVICES, INC. r-� Plaintiff No. , 3 , J �� f 0 ' vs.� c cn CP V -c0 SCOTT DEANER, JR. and AMANDA DEANER N CIVIL ACTION T' Defendant(s) NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY 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. 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 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 AMATO KEA G AND SSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 John R. Keating, Esq., Atty ID #52779 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 1 107 North Commerce Way �� �) b� .�► Bethlehem, PA 18017 (610) 866 -0400 C A DEBT COLLECTION LAW FIRM 1 Ll COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VNB LOAN SERVICES, INC. Plaintiff No. VS. ; SCOTT DEANER, JR. and AMANDA DEANER CIVIL ACTION Defendant(s) COMPLAINT The above Plaintiff brings this action against the above Defendant to recover the sum of $4,085.06, with interest thereon as hereinafter stated, upon the following cause of action: 1. Plaintiff, VNB LOAN SERVICES, INC., is located at 747 Chestnut Ridge Road, Chestnut Ridge, NY 10977. 2. VNB Loan Services, Inc. is a subsidiary of Valley National Bank. 3. Defendant, SCOTT DEANER, JR., is an adult individual located at 1103 Park Place, Mechanicsburg PA 17055. 4. Defendant, AMANDA DEANER, is an adult individual located at 4 Regency Woods i Lane, PA 17015. COUNT r Breach of Contract 5. At the request of Defendants, Harrisburg Hyundai Inc entered into a written contract with Defendants for the purchase of a motor vehicle ( "Contract "), a true and correct copy of which is attached hereto, made a part hereof and marked Exhibit "A." 6. For value received, Harrisburg Hyundai Inc assigned, transferred and set over all of its rights, title and interest in the Contract to Plaintiff. 7. By virtue of said assignment, Plaintiff acquired legal title to Defendants' account and became the holder of all claims against Defendants arising under the Contract. 8. Under the Contract, Defendants agreed to make timely, regular monthly payments to Plaintiff in repayment of all sums loaned to Defendants thereunder. 9. However, Defendants have failed to make timely, regular monthly payments to Plaintiff in repayment of all sums loaned to Defendants under the Contract. 10. Defendants have not adhered to the agreed repayment obligations: set forth in the Contract, by reason of which Defendants are in default thereof. 11. As a result, the subj ect vehicle was repossessed and sold in a commercially reasonable manner and for a commercially reasonable price. 12. The total amount which became due as a result thereof, after allowance for all proper credits for payments and /or adjustments, if any, was $4,085.06. 13. Plaintiff has made demand against Defendants for the aforesaid sums, but Defendants have failed or refused to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against Defendants for $4,085.06 together with costs of suit and all other relief to which Plaintiff may be entitled. COUNT II Alternative to Count I - Unjust Enrichment 14. Plaintiff incorporates the allegations of every paragraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. 15. At Defendants' request, Plaintiff conferred a benefit upon Defendants by providing the auto loan/financing services described in the exhibits attached hereto. 16. Defendants received and accepted the benefit of said services provided by Plaintiff. 17. At all times material hereto, Defendants were aware that Plaintiff was providing the aforesaid services to Defendants and that Plaintiff expected to be paid for such. 18. At all times material hereto, Defendants, with the aforesaid knowledge, permitted Plaintiff to provide said services and to incur damages. 19. At all times material hereto, Defendants were unjustly enriched by retaining the benefit of receiving said services without paying Plaintiff fair and reasonable compensation. 20. Allowing Defendants to retain the benefit of said services without paying fair compensation would be unjust. 21. By reason of the aforesaid unjust enrichment of Defendants at Plaintiff s expense, an implied contract exists between Plaintiff and Defendants 'and Defendants are obligated to pay Plaintiff the quantum meruit value of the services described in the exhibits attached hereto in the amount of $4,085.06. WHEREFORE, Plaintiff demands j udgment against; Defendant for $4,085.06 together with costs of suit and all other relief to which Plaintiff may be entitled. AMATO KEATJNG AND LESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 John R. Keating, Esq., Atty ID #52779 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID 4203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866 -0400 A DEBT COLLECTION LAW FIRM i VERIFICATION F Daniel Wechsler, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff herein; that he is authorized to and does make this verification on behalf of Plaintiff, that he was made acquainted with the facts set forth in the foregoing document by speaking to a representative of the Plaintiff with personal knowledge, information and /or belief about the subject matter of this document and/or by reviewing the relevant supporting documentation; and that the same are true and correct to the best of his knowledge, information and /or belief. This verification is made as such because the Plaintiff was not able to provide an original signed verification within the time allowed to timely file the attached pleading. This verification is made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Dated: October 21, 2013 Daniel Wechsler, Esquire � 1 PENNSYLVANIA q7� �I�� MOTOR VEHICLE INSTALLMENT SALE CONTRACT, Dated : 04/04/07 ANNUAL FINANCE Amount Financed Total of Payments . Total Sale Price PERCENTAGE RATE CHARGE The amount of credit provided The amount you will have paid after you The total cost of your purchase on The cost of your credit as The dollar amount the to you or on your behalf. have made all scheduled payments. credit, including your downpayment a yearly rate. credit will cost you. of $ 1 0.01 10.10 % $ 8990.93 $ 22553.59 $ 31544.52 $ 31544.52 Your Payment Schedule will be: Security: You are giving a security interest in the motor vehicle being No. of Payments Amount of Payments When Payments Are Due purchased. 84 $ 375.53 Monthly, beginning 05/04/07 Prepayment: If you pay off early, you will not have to pay a penalty. $ N I A t Filing Fees: $ 5. Late Charge: If a payment is late, you will be charged 2% of the portion of the payment which is late for each month, or part of a month greater than 10 days, that it remains unpaid. See below and any other Contract documents for any additional information about nonpayment, default, any required repayment in full before the scheduled date.and prepayment refunds and penalties. a means estimate IF YOU DO NOT MEET YOUR CONTRACT In this Contraf{ SBURG HYUNDAI INC OBLIGATIONS, YOU MAY LOSE THE MOTOR we are 4220 CHAMBERS HILL RD HARRISBURG, PA 17111 VEHICLE AND PROPERTY THAT YOU the SELLER. BOUGHT WITH THIS CONTRACT AND /OR Name Address Zip Cade MONEY ON DEPOSIT WITH THE ASSIGNEE. County 8 5961 7 This Contract is between Seller and Buyer. All SCOTT DEARER JR AMANDA DEARER disclosures have been made by Seller- Seller You are 516 QUAIL CT MECHANICSBURG PA 17050 intendsto assign this Contractto the Assignee. the euYER(s). Nam Itemization of Amount Financed Name(s) Address(es) Zip Ccde(s) Cash Price (including optional service County contract and sties in he amount of S � • If there is more than one Buyer, each promise sepa and together, to pay all sums due us and to perform all agreements in this Contract paid to TRADE - IN: &sales tax of$ . 233.92 ). You have traded in the following vehicle: 20ni; = Tf1Y(1TA CORD] I A 2T1 BR32E 16Ih77RSA Cash Price Year and Make Description $ 18377.68 If a balance is still owing on the vehicle you have traded in, the Seller will pay off this amount on your behalf. You warrant and represent to us that Cash Downpayment $ any trade-in is free from lien, claim, encumbrance or security interest, except as shown in the "Itemization of Amount Financed" as the 'Lien Payoff." PROPERTY INSURANCE: You may choose the person through whom insurance is obtained against loss or damage to the Vehicle and against Trade-In liability arising out of use or ownership of the Vehicle. In this Contract, you are promising to insure the Vehicle and keep it insured. Value of Trade -In DEBT CANCELLATION (GUARANTEED AUTO PROTECTION) AGREEMENT IS VOLUNTARY AND NOT REQUIRED AS A CONDITION OF THE $ 14046 CREDIT. This agreement will not be provided unless you sign below, agree to pay the additional charge, and sign the separate disclosure and Lien Payoff to: NIA agreement page, which is part of this Contract. This agreement will apply during the entire term of the Contract. This agreement may not cover $ 17 your entire indebtedness; see the MAXIMUM PROTECTION amount stated in the separate disclosure and agreement. Unpaid Cash Price Balance Type of Debt Cancellation Agreement Charge I Signature $ ., Guaranteed auto protection (GAP) $ Othe , ou select guarante auto protection Optional Debt Cancellation (GAP) 600 -00 $ B r Document Preparation Fee SERVICE CONTRACT OR WARRANTY AGREEMENT IS VOLUNTARY AND NOT REQUIRNDITION OF THE CREDIT. The service contract $ or warranty agreement will not be provided unless you sign the separate agreement rd party provid er, who is not the Seller named Paid to Others on Your Behalf above, and agree to pay the additional charge. This section does not apply to any warranty that you may receive for which there is not separate charge. To Public Officials for: CREDIT INSURANCE IS NOT REQUIRED: Credit Life Insurance and Credit Accident &Health (Disability) Insurance are not required to obtain License, Tags and Registration $ credit, and will not be provided unless you sign below and agree to pay the additional cost(s). Please read the NOTICE OF PROPOSED CREDIT Sn INSURANCE on the reverse side. Your insurance certificate or policy will tell you the MAXIMUM amount of insurance available. All insurance Lien Fee purchased will be for the term of the credit. We may receive a financial benefit from your purchase of credit insurance. $ By signing, you select Single Credit Life Insurance, What is your By signing, you select Single Credit Accident & What is your Taxes Not Included in Cash Price T I R which costs $ age? Years Health Insurance, which costs $ age? Years $ To Signature of Buyer to be, insured for Single Credit Life Insurance Signature of Buyer to be insured (or Single Credit Accident & Health Insurance $ NIA By signing, you both select Joint What are By signing, you both select Joint Credit For Messenger Service Credit Life Insurance, which costs $ Accident & Heanh Insurance, which costs What are Percentage To your ages . $ - your ages. to be EXHIBIT insured $ % For J J Q Life Insurance Credit Accident & Health Insurance TD ('VR Insurer: S 10.00 VEHICLE: You have agreed to purchase, under the terms of this Contract, the following motor vehicle and its extra equipment, which is called For the "Vehicle" in this Contract. To " DEALER N/U Year and Make ri S tiodv Style No. CCV1. Truck Ton Capacity Serial Num er g + 15.00 USED 2006HYUNDAI SOMATA SNPEU46f=86HO88904 For ) Equipped — A.T. _ P.S. — AM -FM Stereo 5 Spd. Other To With _ A.C. _ P.W. ^ AM -FM Tape Vinyt Top $ N / A ASSIGNEE: We may assign this Contract and Security Agreement to a sales finance company which is the "Assignee." If the Assignee assigns For the Contract to a subsequent assignee, the term also refers to such subsequent assignee. After the assignment, all rights and benefits of the To Seller in this Contract and in the Security Agreement shalt belong to and be enforceable by the Assignee. The Assignee will notify you when S N/A ' and if Seller makes an assignment. For VALLEY NATIONAL BANK. 1445 Valley Road, Wayne. NJ 07470 To CO- SIGNER: Any person signing the Co- Signer's Agreement below promises separately and together with all Co- Signers) and Buyer(s), to pay $ N/A all sums due and to perform all agreements in [his Contract Co- Signer will not be an Owner of the Vehicle. For CO- OWNER: Any person signing the Co- Owner's Security Agreement below gives us a security interest in the Vehicle and agrees separately and Amount Financed together with all Co- Owners) and Buyer(s), to perform all agreements in the Security Agreement and all other parts of this Contract except the $ "Promise to Pay" section. r TERMS: The terms shown in the boxes above are part of this Contract. We may retain a portion of amounts marked* PROMISE TO PAY: You agree to pay us the Total Sale Price for the Vehicle by making the Cash Downpayment and assigning the Trade -In, it shown above, on or before the date of this Contract, and paying us the Amount Financed plus interest You promise to make payments in accordance with the Paymeni Schedule. You promise to make payments on or before the same day of each month as the first payment due date. You agree to pay all other amounts which may become due under the terms of this Contract. You agree 10 pay the Seller or Assignee costs of suit. You also agree to pay reasonable attorneys' lees it Seller or Assignee hires an attorney to collect amounts due under this Contract or to protect or get possession of the Vehicle. You agree to make payments at the place or to send payments to the address which the Assignee most recently specifies in the written notice to you. The Annual Percentage Rate may be negotiable with the Seller. ADDITIONAL DISCLOSURES, TERMS AND CONDITIONS: The Seller may assign this contract aild retain its right to Disclosures: Before signing this Contract, be sure that you receive and read the Disclosure to Buyer. receive a part of the Finance Charge. Terms and Conditions: Before signing this Contract, be sure you receive and read the following, it marked X, which are additional pages to and part of this Contract. ® This Contract continues on the reverse side. Debt Cancellation (guaranteed auto protection) separate disclosure and agreement By signing below, we agree to sell the Vehicle to you under the terms of this Contract. NOTICE TO BUYER —DO NOT SIGN THIS CONTRACT IN BLANK. YOU ARE ENTITLED TO AN EXA T COPY OF THE CONTRACT YOU SIGN. KEEP IT TO PROTEYOU LEG RIGH SELLER HARRISBURG HYUNDAI INC BUYER . (SEAL) Date BY: 04/04/0 BUYER ,4 (SEAL) 4/04 Date Date CO -SIGN R: YOU SHOULD dEAD T NOTICE TO CO- SIGNER, WHICH HAS BEEN GIVEN TO YOU ON A SEPARATE DOCUMENT, BEFORE SIGNING THE CO- SIGNER'S AGREEMENT. CO- SIGNER'S AGREEMENT: You, the person (or persons) signing below as "Co- Signer," promise to pay to us all sums due on this Contract and: to perform all agreements in this Contract. You intend to be legally ound.by all the terms of this Contract, separately and together, with the Buyer. You are making this promise to induce us to make this Contract with the Buyer, even though we will use the proceeds only for the Buyer's benefit. You agree to pay even though we may not have made any prior demand for payment on the Buyer or exercised our seeurity interest. You also acknowledge receiving a completed copy of this Contract. (SEAL) Co- Signer's Signature Address Date (SEAL) Co- Signer's Signature Address Date CO- OWNERS SECURITY AGREEMENT: You, the person signing below as "Co- Owner," together with the Buyer or otherwise being all of the Owners of the Vehicle, give us a security interest in the Vehicle identified above. You agree to be bound by the terms of the Security Agreement and all other parts of this Contract except the "Promise To Pay ".section, You are giving us the security interest to induce us to make this Contract with the Buyer, and to secure the payment by the Buyer of all sums due on this Contract. You will not be responsible for any deficiency which might be due after repossession and sale of the Vehicle. (SEAL) Co- Owner's Signature Address 1700a 4/( BUYER, CO- SIGNER AND CO- OWNER, IF APPLICABLE, ACKNOWLEDGE RECEIPT OF A COMPLETED COPY. OF THIS CONTR CT T THE TIME OF SIGNING, INCLUDING THE ADDITIONAL DISCLOSURES AND PAGES LISTED IN THE SECTION LL DITIONAL DISCLOSU S, TERM AND C NDITIONS. BUY 8 ER CO- SIGNER CO- SIGNER OR CO-OWNER NOTICE: SEE REVtRSE SfDE FOR IMPORTANT INFORMATION. BANCONSUMER FORM PA 123DC-SLC 12!94) ORIGINAL - White • OEALCR COPY • Cinary - BORROWER'S /COSIGNER'S COPY - PinM - COPY - Goldenrod ° 2004 BANCONSUMER SERVICE, INC. ADDITIONAL TERMS 06COND1$ONS 1. SECURITY AGREEMENT To secure the payment of all sums due and the performance of 11. OUR RIGHTS IF YOU BREAK YOUR PROMISES ABOUT THE SECURITY INTEREST, all required obligations under this Contract, you give a security interest in the Vehicle, in all VEHICLE'OR INSURANCE: II you fail to keep your promises to pay filing fees, taxes, liens or parts (called "accessions ") attached to the Vehicle at any later time, and in any proceeds of the costs necessary to keep the Vehicle in good condition and repair, we may advance any the Vehicle, including insurance proceeds. The Assignee may set -off any amounts due and money you promised to pay. If you fail to keep your promises about required_ insurance, we unpaid under this Contract against any of your money on deposit with Assignee. This includes may advance money to obtain insurance to cover loss or damage to the Vehicle: We have the any money which is now or may in the future be deposited with Assignee by you. Assignee choice of whether or not to advance any money for these purposes. Such insurance will be may do this without any prior notice to you. limited to an amount not greater than you owe on this Contract. THE INSURANCE WE 2. HOW THE TOTAL OF PAYMENTS IS COMPUTED: The Total of Payments is the sum of the PURCHASE MAY BE SIGNIFICANTLY MORE EXPENSIVE AND PROVIDE YOU LESS COVERAGE Amount Financed and the Finance Charge. The Finance Charge consists solely of interest THAN INSURANCE YOU COULD PURCHASE YOURSELF. computed daily on the outstanding balance of the Amount Financed. The Finance Charge We will add any money we advance on your behalf to the balance on which we impose shown on the front side has been computed on the assumption that we will receive all Finance Charges at the Annual Percentage Rate of this Contract. You agree to repay the payments on their scheduled due dates. money advanced as we alone may specify: (i) immediately on demand, or (ii) along with your 3. COMPUTING INTEREST: We will charge interest on a daily basis on the outstanding. monthly payments. If we choose to allow you to repay the money advanced along with your balance subject to interest on each day of the loan term, including any period for which a late monthly payments, we can choose the amount of these payments and how long you have to charge is also imposed. The daily interest rate is equal to the Annual Percentage Rate divided repay. If any of our rights stated in this paragraph are not permitted by law, we still have the by the number of days in that calendar year. Buyer agrees that because interest is calculated other rights mentioned. Our payments on your behalf will not cure your failure to perform on a daily basis, late payments will result in additional interest (and, if applicable, a late your promises in this Contract. charge). Early payments will result in less interest being charged. Early and /or late payments 13. DEFAULT: In this paragraph "You" means the Buyer, Co- Signer and Co- Owner, or any one will cause the amount of the final payment to change. of them. You will be in "Default" of the Conlracl if any one or more of the following things 4. LATE CHARGE: Buyer agrees to pay a tale charge for any payment not made within 10 happen: days after its due date. The late charge will be 2% per month on the unpaid amount of the a. You do not make any payment on or before it is due; or payment. We will consider any part of a month in excess of 10 days to be a full month. The b. You do not keep any promise you made in this Contract; or late charge will be due when earned. No late charge will be due if the reason that the c. You do not keep any promise you made in another Contract, Note, Loan or Agreement payment is late is because, after default, the entire outstanding balance on this Contract is with Seller or Assignee; or due. No late charge will be due if the only reason that the payment is late is because of a late d. You made, any untrue statement . in the credit application for this Contract; or charge assessed on an earlier payment. e. You committed any forgery in connection with this Contract; or 5. APPLICATION OF PAYMENTS: We will apply I. You die, are convicted of a crime involving fraud or dishonesty, or are found by a court pp y payments in the following order of priority: with jurisdiction to do so to be incapacitated; or first to interest; and then to late charges, fees, principal and any other amounts you owe in g. You file bankruptcy or insolvency proceedings, or anyone files bankruptcy or the order that we choose. insolvency proceedings against you or 6. PREPAYMENT: You may prepay, in full or in part, the amount owed on this Contract at any h. You lake the Vehicle outside the United States or Canada without our written consent; or time without penalty. It you prepay the Contract in part, you agree to continue to make i. You use the Vehicle or allow someone else to use it in a way that causes it not to be regularly scheduled payments until you pay all amounts due under this Contract. This will covered by your insurance; or reduce the number of payments you will make. I. You do something that causes the Vehicle to be subject to confiscation by government 7. WAIVERS. authorities; or a. WAIVER BY SELLER AND ASSIGNEE: We and Assignee waive the right to treat any k. The Vehicle is lost, stolen, destroyed or damaged beyond economical repair, and not property as security for the repayment of this Contract, except for the Vehicle and the other fixed or found within a reasonable time; or. security specifically mentioned in this Contract 1. Another creditor tries to take the Vehicle or your money on deposit with Assignee by b. WAIVERS BY BUYER, CO- SIGNER AND CO. OWNER: You agree to make all payments on legal process. or before they are due without our having to ask. If you don't, we may enforce our rights. 14. OUR RIGHTS IF YOU ARE IN DEFAULT .OF THIS CONTRACT: If you are in Default of this without notifying you in advance. You give up any right you may have to require that we Contract, we may enforce our rights according to law. We may also do the things specifically enforce our rights against some other person or property before we enforce our rights against mentioned in this Contract. We may do one of these things and at the same time or later do you. You agree that we may give up our rights against some other person but not against you. another. Some of the things we may do are the following: You waive due diligence in collection and all defenses based on suretyship and impairment of a. ACCELERATION: We can demand. that you pay to, us the entire unpaid balance owing collateral or security. on the Contract and all unpaid Finance Charges and other money due. You agree that you will 8. INTEREST AFTER MATURITY AND JUDGMENT: Interest at the rate provided in this pay this money to us in one single payment immediately upon receiving our-demand. Contract shall continue to accrue on the unpaid balance until paid in full, even after maturity b. REPOSSESSION: We can repossess the Vehicle, unless prohibited by law. We can do and /or after we get a judgment against you for the amounts due. This will apply even if the this ourselves, have a qualified person do it for us, qr have a government official (by replevin) maturity occurs because of acceleration. If at any time interest as provided for in this do it for us. You agree that we can peaceably come on to your property to do this. We may paragraph is not permitted by law, interest shall accrue at the highest rate allowed by take any other-things found in the Vehicle, but will return these things to you if you ask. If you applicable law beginning at that time. want these things back, you may reclaim them within thirty (30) days of our mailing you a 9. YOUR PROMISES ABOUT OUR SECURITY INTEREST: You will not permit anyone other Notice of Repossession. If you do not reclaim the things found in the Vehicle within that time, p Y we may dispose of those things in the same manner as the motor vehicle. You agree that we than us to obtain a security interest or other rights in the Vehicle. You will pay all filing lees may use your license plates in repossessing the Vehicle and taking it to a place for storage. necessary for us to obtain and maintain our security interest in the Vehicle. You will assist us' c , VOLUNTARY DELIVERY: We can ask you to give us the Vehicle at a - reasonably in having our security interest noted on the Certificate of Title to the Vehicle. You will not sell convenient place. You agree to give us the Vehicle it we ask. or give away the Vehicle. If someone puts a lien on the Vehicle, you will pay the o5ligation and d. DELAY IN ENFORCEMENT: We can delay enforcing our rights under this Contract clear the lien. out losingiany rights. 10. YOUR PROMISES ABOUT THE VEHICLE: You will keep the Vehicle in good conditioni and s SOME THINGS YOU SHOULD KNOW IF WE REPOSSESS THE VEHICLE: It we repossess repair. You will pay all taxes and charges on the Vehicle. You will pay all costs of maintaining without using a government official (by replevin): the Vehicle. You will not abuse the Vehicle or permit anything to be done to the Vehicle which a. NOTICE: We will send you a Notice of Repossession to your last address we know about. will reduce its value, other than for - normal wear and use. You will not use the Vehicle for This Notice will tell you how to buy back (redeem) the Vehicle. You will NOT have the right to illegal purposes or for hire or lease. You will not move the Vehicle from your address shown on reinstate the Contract This means you will have to pay the total balance on the Contract and the front of this Contract to a new permanent place of garaging without notifying us in other amounts due. You may not get the Vehicle back by paying delinquent installments. This advance. Notice will tell you other information required by law. 11. YOUR PROMISES ABOUT INSURANCE: You will keep the Vehicle insured against fire, b. REDEMPTION: You have the right to buy back (redeem) the Vehicle within 15 days of theft and collision until all sums due us are paid in full. The insurance coverage must be the mailing of the Notice and at any later time before we sell the Vehicle. If you redeem the satisfactory to us and protect your interests and our interests at the time of any insured loss. Vehicle, we will deliver the Vehicle to you at a place as provided by law; as soon as is The insurance must name us as "loss payee" on the policy. The insurance must be written by reasonably possible, but in not more than ten (10) business days of our receipt of the funds an insurance company qualified to do business in Pennsylvania and licensed to sell insurance required. If you do not redeem, you give up all claim to the Vehicle. in the.state where the Vehicle is permanently garaged. The insurance policy must provide us c. SALE:.If you don't redeem, we will sell the Vehicle. The money received at sale will be with at least ten (10) days prior written notice of any cancellation or reduction in coverage. On used to pay costs and expenses you owe, and then to pay the amount you owe on the request, you shall deliver the policy or other evidence of insurance coverage to us. In the Contract event of the loss or damage to the Vehicle, you will immediately notify us in writing and file a d. SURPLUS OR DEFICIENCY: If there is money left, we will pay it to the Buyer: It there is proof of loss with the insurer. not enough money from the sale to pay what you owe, Buyer and Co- Signer agree to pay what a. OUR RIGHT TO FILE PROOF OF LOSS: In the event of any loss or damage to the is still owed to us. Vehicle, if you fail or refuse to file a claim or proof of loss with the insurance company, you e. EXPENSES: You agree to pay the costs of repossessing, staring, repairing, preparing for agree that the Seller, Assignee, any subsequent assignee, or any authorized employee of any sale and selling the Vehicle as may be allowed by law. These costs will only be due if: of them ( "we ") may file a proof of loss with the insurance company, in your name and acting 1. Default exceeds fifteen (15) days at the time of repossession; ...:,� ------ I ♦_ Iy, v..., Tk. n/ ­tr orc orh,�l mrnq,ron, an�i roarnnnhlo• �n�i 1 i I ' i I dsyuurdgdnr, nrtn iwpcor ru aic mw;cu OJI.-tuu dgret uidcyuu uv nVi ndvd I. It; ngm w, . , ��,,• �• °, ° °, , °� ''� ° "� ° ° °� " and will mot, revoke the power you have given us to file a proof of loss. You agree that we may 3. We can prove the costs were paid. exercise this power for our benefit and not for your benefit, except as provided in this 16. HEIRS AND PERSONAL REPRESENTATIVES BOUND: After your death, this Contract shall Contract and by law. be enforceable against your heirs and personal representatives of your estate. • b. OUR RIGHT TO ENDORSE INSURANCE CHECKS: You agree lhat.lhe Seller, Assignee, 17. GOVERNING LAW: This Contract is to be interpreted according to the law of Pennsylvania. any subsequent assignee, or an authorized employee of any of them ( "we ") may. endorse your name, acting as your agent, to any check, draft or other instrument we receive in payment of 18. SEVERABILITY OF PROVISIONS: If for any reason any part of this Contract shall become an insured loss or return of insurance premiums. You agree that you do not ha4e the right lo, illegal, void or unenforceable, that part shall not be a part of this Contract. and will.not, revoke the power you have given us to make your endorsement. You agree that 19 ASSIGNMENT BY BUYER: Buyer shall not assign this Contract we may exercise this power for our benefit and not for your benefit, except as provided in this 20. THERE ARE NO WARRANTIES BY SELLER; EXPRESSED OR IMPLIED, INCLUDING THE Contract and bylaw: WARRANTIES Of MERCHANTABILITY AND FITNESS.FOR A PARTfCULAR.PURPOSE, c. USE OF PROCEEDS: We may apply any insurance proceeds we receive to repair or replace the Vehicle if, in our opinion, it is economically feasible and you are not then in UNLESS WE HAVE GIVEN YOU A SEPARATE WRITTEN WARRANTY OR UNLESS SELLER default of this Contract. Otherwise, we will apply the insurance proceeds to reduce the unpaid ENTERS INTO A SERVICE CONTRACT WITH BUYER WITHIN 90 DAYS FROM THE DATE OF balance due us. After the balance due us is paid, any excess will belong to you.. THIS CONTRACT, Buyer's Guide Window Sticker. If the Car which is described on the face of this Contract has a Buyer's:Guide Window Sticker required by the Federal Trade Commission Used Car Trade'Regulation Rule, the following notice applies: The information you see on the window form for this Vehicle is part of this Contract. Information on the window form overrides any contrary provisions in the contract of sale. NOTICE�ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. NOTICE OF PROPOSED CREDIT INSURANCE The signer(s) of this Contract hereby take(s) notice that Group Credit life Insurance coverage or Group Credit Accident and Disability Insurance coverage will be applicable to this Contract if so marked on the front of this Contract; and each such type of, will.be. written by the insurance company named. This insurance, subject to acceptance by the insurer, covers only the person or persons signing the request for such insurance. The amount of charge is indicated for each type of Credit Insurance to be purchased. The term of insurance will commence as of the date the indebtedness is incurred and will expire on the original scheduled maturity date of the indebtedness. Subject to acceptance by the insurer and within 30 days, there will be delivered to the insured debtor( a certificate of insurance more fully describing the insurance. In the event of prepayment of the indebtedness, a refund of insurance charges will be made when due. NOTICE: SEE OTHER SIDE FOR IMPORTANT INFORMATION. THE PROVISION BELOW IS NOT PART OF THE PENNSYLVANIA MOTOR VEHICLE INSTALLMENT SALE CONTRACT BETWEEN THE BUYER AND SELLER. ASSIGNMENT fo induce you, the "Assignee" identified on the face of this Contract or as follows, (Name) to purchase the within Contract, the Seller hereby warrants and represents, and continues to warrant and represent that: the sale has been made in strict conformity with all applicable federal, state and local laws and regulations, including, but not limited to, Article 2 of the Pennsylvania Uniform Commercial Code (13 Pa. C.S.A. § §2101 et seq); our title to the Contract and the Vehicle covered thereby is absolute, free of all liens, encumbrances and security interests, and is subject only to the rights of the Buyer as set forth therein; the Contract is genuine, the signatures thereon are not forgeries, arose from the sale of the Vehicle therein described, and all parties thereto are of full age and had capacity to contract; the description of the Vehicle and extra equipment is complete and correct; the cash downpayment and /or trade-in allowance were actually received and no part thereof consisted of notes, post -dated checks, other credit advanced by us to Buyer or rebates or similar payments from us to the Buyer (however manufacturer rebates may constitute all or a part of the downpayment); all warranties and statements therein are true; there is owing thereon the Amount Financed plus interest at the Annual Percentage Rate of the Contract set forth therein; we are duly licensed under the Pennsylvania Motor Vehicle Sales Finance Act and.have duly complied with all requirements thereof with respect to the transaction and with the federal Truth -in- Lending Act and with any other federal or state law, rule or regulation applicable to -this Contract; a.molor vehicle title certificate showing a lien or encumbrance in favor of Assignee has been or will be applied for promptly; the registration of the Vehicle has not been suspended and the Seller knows of no facts which may result in the suspension of said registration under the Pennsylvania Motor Vehicle Financial Responsibility Act; the Buyer(s) named in the within Contract is (are) personally known.to.the Sellerto be the same identical person(sl whose signaturets) is (are) affixed to this Contract; and Seller has no knowledge of facts impairing the validity or value of the Cohtradt. If any such warranties or representations should be breached at any time, Seller shall repurchase said Contract from Assignee; aerriand, and will pay therefor, in cash, the amount..owing thereon, computed as set torth below, and said remedy shall be cumulative and not exclusive, and shall not affect any olhe t or remedy that Assignee might have at law . .or in'equify against Seller.. In the event that Buyer fails or refuses to -make any payment due hereunder on the assertion, either oral or w Itten, that the Vehicle is defective, not as represented to the Buyer by Seller, or that Seller refuses to honor any warranty or service agreement of Seller or manufacturer, Seller agrees that, on being advised by Assignee of such claim 6f.6uyer, Seller will repurchase the Contract from Assignee and pay Assignee for same immediately in accordance with the repurchase terms set forth below, and Seller further agrees to hold Assignee harmless from any other claims of Buyer, including attorneys' fees, costs and expenses incurred in defending against claims asserted by Buyer and including claims for refund of payments made by Buyer to Assignee. It the Seller contracts to purchase property insurance on behalf of the Buyer, and that insurance is Cancelled by the insurance company prior to its scheduled expiration date, Seller will attempt to place comparable coverage with another insurance company on behalf of.the Buyer. 11 Seller is.unable to do so, Seller will notify Buyer and pay to Buyer any additional costs incurred by the Buyer in obtaining replacement insurance for the unexpired period of the original insurance policy. By signing and dating the Contract, as Seller, delivering the Contract to the Assignee and accepting payment for it, Seller authorizes the Assignee to act as the Seller's agent for the purpose of completing or correcting the identification of the Assignee in this Assignment to reflect the true Assignee who purchased the Contract and /or for the purpose of signing Seller's name to this Assignment, without recourse, it the Assignment is delivered without the Seller's signature. Assignee may exercise the power given in this paragraph . for the benefit of the Assignee and not for the benefit of the Seller. Seller does not have the right to and agrees not to revoke the power given in this paragraph. In the event that Seller is required by this Assignment to repurchase the Contract and /or Vehicle, Seller shall pay to Assignee, in cash, the full unpaid balance of the Contract as of the date of repurchase, plus any then earned Finance Charge and any and all costs and expenses paid or incurred by Assignee in respect thereto, including reasonable attorneys' fees, in connection with claims by or against any Buyer, Owner or persons in possession of the Vehicle and /or by or against Seller. For value received, Seller hereby sells, assigns and transfers unto the Assignee, its successors and assigns, the within Contract, all moneys due and to become due thereunder, and all right, title and interest in and to the Vehicle therein described, with full power in the Assignee in its or our name to take such legal or other action which we might have taken save for this Assignme,at. Unless Seller marks either of the endorsements below, titled "WITH FULL RECOURSE" or "WITH REPURCHASE," Seller's assignment shall, except for the provisions of the paragraph titled "Assignment;' be without recourse. ❑ WITH FULL RECOURSE — Seller agrees that, in addition t0 the paragraph above titled "Assignment;' in the event of default by Buyer in the full payment on the due date thereof of any installment payable under the Contract or in the prompt performance of any other obligation to be performed under the Contract by Buyer, Seller will, on demand by Assignee, forthwith repurchase the Contract from Assignee for a repurchase price, in cash; computed as set forth above. ❑ WITH REPURCHASE — Selfer agrees that, in addition to the provisions of the paragraph above titled "Assignment;' in the event of any default by Buyer which shall entitle Assignee to repossess the Vehicle, Seller will, if the Vehicle is repossessed by Assignee and delivered to Seller, and without regard to the then condition of the Vehicle, forthwith repurchase the Contract and the Vehicle from Assignee for a repurchase price, in cash, computed as set forth above. By signing below, we agree to the terms of the Assignment. Seller By Date 9ANCONSUMER FORM PA 1230C -SLC (2/041 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW f VNB LOAN SERVICES, INC. 2 a�V, Plaintiff -0a Q @" VS. SCOTT DEANER, JR. and - AMANDA DEANER CIVIL ACTION Defendant(s) —�y ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Plaintiff, VNB LOAN SERVICES, INC., in the above - captioned matter. AMATO KE T G D LESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 John R. Keating, Esq., Atty ID #52779 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID 4309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866 -0400 A DEBT COLLECTION LAW FIRM Dated: October 21, 2013 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff P0jj� 1 ���l�ttr rt �a�artlarrt,��� Jody S Smith �] Chief Deputy g ' � 20 13 NOV 18 PII 2• }. tiMBLAt CUJ Richard W Stewart Solicitor feFFICE CF THE sI R1F- PENNSYLVANIA VNB Loan Services, Inc. vs. Case Number Scott Deaner, Jr. (et al.) 2013-6329 SHERIFF'S RETURN OF SERVICE 10/29/2013 08:54 PM - Deputy Ryan Burgett, 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: Scott Deaner, Jr. at 1103 Park Place, Monroe Township, Mechanicsburg, PA 17055. n RYAN BURGETT, DE 11/05/2013 05:27 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Amanda Deaner, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint&Notice as"Not Found" at 4 Regency Woods Lane, Middlesex Township, Carlisle, PA 17015. Deputies were advised by resident of Lot#4 that the Township just renamed all of the roads and there is no Regency Woods Lane and he did not know Amanda Deaner. SHERIFF COST: $67.08 SO ANSWERS, K � X 2��, November 06, 2013 R-ONW R ANDERSON, SHERIFF iGj^ew�ty ure Shenfi,Tei?gseft..;^c. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VNB LOAN SERVICES, INC. Plaintiff No. 13-6329 VS. SCOTT DEANER, JR. and AMANDA DEANER CIVIL ACTION Defendant NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT SCOTT DEANER, JR. ONLY IN THE AMOUNT OF $4,272.39 ON j� /13 2013. ( ) A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY - CUMBERLAND COUNTY If you have any questions concerning the above, please contact the undersigned. AMATO KEATI LESSA, P.C. By: -(:� r Michael R. Lessa, Esq., Atty ID #88617 John R. Keating, Esq., Atty ID #52779 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM /4.,.s,Z)'P� . �/ 412 h IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VNB LOAN SERVICES, INC. Plaintiff No. 13-6329 VS. C":1 ey - - { SCOTT DEANER, JR. and AMANDA DEANER _ N) CIVIL ACTION <';' °' ::. Defendant —� - - a-C PRAECIPE FOR JUDGMENT ` TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment by default for want of an answer in favor of Plaintiff and against the above-named defendant SCOTT DEANER, JR. ONLY and assess damages as follows: Debt $4,085.06 Costs $187.33 Total $4,272.39 1 CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. Pursuant to RCP 237.1 , 1 certify that a copy of the annexed written notice(s) of intention to file this praecipe was mailed or delivered to all parties against whom judgment is to be entered and to their attorney of record, if any, after the default occurred, and at least ten days prior to the date of filing of this praecipe. Please note that said notice was mailed to all parties on November 22, 2013. Dated: December 17, 2013 AMATO KEAT LESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 John R. Keating, Esq., Atty ID #52779 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM 2131238 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VNB LOAN SERVICES, INC. Plaintiff No. 13-6329 vs. SCOTT DEANER, JR. and AMANDA DEANER CIVIL ACTION Defendant CERTIFICATION OF ADDRESSES do certify that the precise last known address of the within named plaintiff is: 747 Chestnut Ridge Road Chestnut Ridge NY 10977 1 do certify that the precise last known address of the within named defendant is: 1103 Park Place Mechanicsburg PA 17055 AMATO KEATI ESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 John R. Keating, Esq., Atty ID #52779 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VNB LOAN SERVICES, INC. Plaintiff No. 13-6329 VS. SCOTT DEANER, JR. and AMANDA DEANER CIVIL ACTION Defendants AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON : The undersigned, being duly sworn, according to law, deposes and says that he is unable to determine whether or not the above Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of The Servicemembers Civil Relief Act; That Scott Deaner, Jr. is over 18 years of age, resides at 1103 Park Place, Mechanicsburg PA 17055. Sworn to and subscribed before me this ),FN'day of D-P-c 2013 A.D. NOTARY PUBLIC COMMONWEALTH H OF PENNSYLVANIA Notarlal Seal Michelle C.Bright,Notary Public City of Bethlehem,Northampton County My Commission Expires June 6,2015 MEMBER,PENNSYLVANIA ASSOEIATTON OF OTARIES COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VNB LOAN SERVICES, INC. Plaintiff No. 13-6329 vs. SCOTT DEANER, JR. and AMANDA DEANER Defendants TO: Scott Deaner, Jr. 1103 Park Place Mechanicsburg PA 17055 Date of Notice: November 22, 2013 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO KEATING A-ND LESSA, P.C. Michael R. Lessa, Esq., Atty ID #88617 John R. Keating, Esq., Atty ID #52779 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File# 2131238 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VNB LOAN SERVICES, INC. Plaintiff No. 13-6329 vs. - M Ca c.- mm SCOTT DEANER, JR. and r") AMANDA DEANER -t> X- C:' CIVIL ACTION Defendant(s) =C:) u, - PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the complaint in the above-captioned case for defendant Amanda Deaner, only. AMATO KEATING AND L SSA, P.C. By: . Mic el R. Les , Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM 0-!_i> a �l. Z,, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f - �a w i it.. Sheriff �4t i9ttrata ,t i�. _' Z ,�� Jody S Smith Chief Deputy 2014FEB 28 P J Richard W Stewart Solicitor 3 ..4t,;4-z CUMBERLAND CO T v PENNSYLVANIA VNB Loan Services, Inc. vs. Case Number Scott Deaner, Jr. (et al.) 2013-6329 SHERIFF'S RETURN OF SERVICE 02/05/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Scott Deaner, Jr., but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Found"at 4 Helena Lane, Regency Woods North, Carlisle, PA 17015. Current resident purchased home in November 2013. To this date,the Carlisle Postmaster has been unable to provide an updated address and the Writ has since expired. SHERIFF COST: $39.78 SO ANSWERS, February 24, 2014 RONIW R ANDERSON, SHERIFF JSO i COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW .f VNB LOAN SERVICES,INC. i Plaintiff No. 13-6329: vs. SCOTT DEANER,JR. and c: AMANDA.DEANER CIVIL ACTION Defendant(s) z PRAECIPE TO REINSTATE COMPLAINT i I ' TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the complaint in the above-captioned case. i AMATO KEATING AND LESSA, P.C.' By: Mic el R. Les , Esq.,'"Atty ID #88617 Justin N. Davis, Esq., Atty ID:#84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff { 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM S-. co 3Y9?'7.3 I SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ' LEO--,OFFICE ii Sheriff r #" fl-trrHo NO i.:rz',t. Jody S Smith Chief Deputy Richard W Stewart Solicitor OFM4OF EHE;�S 2014 APR 28 PI 2.51= CUMBERLAND COUNTY PENNSYLVANIA VNB Loan Services, Inc. vs. Scott Deaner, Jr. (et al.) Case Number 2013 -6329 SHERIFF'S RETURN OF SERVICE 03/28/2014 01:13 PM - Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Amanda Deaner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 602 Allenview Drive, Upper Allen Township, Mechanicsburg, PA 17055. Deputies were advised by the defendant's father that the defendant moved out several months ago and the Mechanicsburg Postmaster states that mail is delivered to the address provided. SHERIFF COST: $44.79 SO ANSWERS, April 16, 2014 RONNY R ANDERSON, SHERIFF (c)CountySuite Sherifi,"ieeo