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HomeMy WebLinkAbout14-3086 h, L BURTON NEIL& ASSOCIATES, P.C. "° By: Derek Blasker, Esquire, Id. No. 202150 ' 1060 Andrew Drive, Suite 170 22 # ' West Chester, PA 19380 17" 610-696-2120 p jj} ',;VA 1j' 7-Y Attorney for Plaintiff DYNAMIC LEGAL RECOVERY assignee IN THE COURT OF COMMON PLEAS of RELIABLE FINANCE COMPANY LLC Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. - 'L NO. N-1 Jv�� V l NEWBURG TRANSPORT, INC. and SHANNON BLACK AND ERICK BOOZ Defendants : IN CONFESSION OF JUDGMENT Confession of Judgment Pursuant to the authority contained in the warrant of attorney, a copy of which is contained in the Demand Note, attached as Exhibit 2 to the Complaint in this action, I appear for the defendants, Shannon Black, Erick Booz, and Newburg Transport, Inc., and confess judgment in favor of the plaintiff, Dynamic Legal Recovery assignee of Reliable Finance Company, LLC, against defendants, Shannon Black, Erick Booz, and Newburg Transport, Inc., as follows: Principal Balance Remaining on the Note $34,619.49 Interest at 15%per annum from March 9, 2012 through May 16, 2014 11,353.30 Collection Costs 6,923.90 TOTAL $52,896.69 Which judgment shall continue to accrue inter st t 15%per annum, until the judgment amount is paid in full. BURTO &ASSOCIATES, P.C. By. Derek C. sker, Esquire Attorney for aintiffP, 1 �(�jp• Q Zap a0S NS YL VA 1�� Burton Neil&Associates, P.C. By:Derek C. Blasker,Esquire ID.NO.202150 1060 Andrew Drive, Suite 170 West Chester,PA 19380 (610)696-2120 Attorney for Plaintiff DYNAMIC LEGAL RECOVERY, assignee IN THE COURT OF COMMON PLEAS of RELIABLE FINANCE COMPANY LLC Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NEWBURG TRANSPORT,INC.And :NO. 3t/�`� lir I� 1"2 SHANNON BLACK AND ERICK BOOZ Defendant : IN CONFESSION OF JUDGMENT Complaint-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(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 claim set forth against you. You are warned that if you fail to do so,the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 175135 Burton Neil & Associates, P.C. Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for: Plaintiff DYNAMIC LEGAL RECOVERY assignee IN THE COURT OF COMMON PLEAS of RELIABLE FINANCE COMPANY LLC 23236 Lyons Avenue #220 Santa Clarita, California 91321 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. / �30�i CIL- NEWBURG TRANSPORT, INC. 25 Turnpike Road Newburg, Pennsylvania 17240 and SHANNON BLACK 25 Turnpike Road Newburg, Pennsylvania 17240 AND ERICK BOOZ 233 Booz Road Shippensburg, Pennsylvania Defendants : IN CONFESSION OF JUDGMENT Complaint 1. The plaintiff is Dynamic Legal Recovery, assignee to Reliable Finance Company, LLC with place of business located at 23236 Lyons Avenue #220, Santa Clarita, California 2. The defendant is Newburg Transport, Inc. with place of business located at 25 Turnpike Road,Newburg, Cumberland County, Pennsylvania. 3. The defendant is Shannon Black with place of residence located at 25 Turnpike Road, Newburg, Cumberland County, Pennsylvania. 4. The defendant is Erick Booz, with a place of residence located at 233 Booz Road, Shippensburg, Cumberland County, Pennsylvania. 5. On or about March 9, 2012, Newburg Transport, Inc., by and through its principal Erick Booz, completed an Application for Credit, which application was for the request of a loan from Reliable Finance Company, LLC. A copy of the Application for Credit is attached hereto, made a part hereof, and is marked Exhibit 1. 6. On or About March 9, 2012, Eric Booz and Shannon Black executed a Demand Note for a loan issued to Newburg Transport, Inc., which loan was in the amount of$41,251.59. The original Demand Note is not available, attached as Exhibit 2 is a true and correct copy of the Demand Note. 7. Plaintiff accepted the Note in consideration of defendants' promise to make timely payments thereunder and to'permit defendants to pay the acknowledged and admitted principal sum amount. 8. The Note, executed by Newburg's principals, Erick Booz and Shannon Black, contained language that allowed for the confession to judgment, in the event of default. 9. As evidenced by the Demand Note, Judgment herein is not being entered by confession against a natural person in connection with a consumer credit transaction. 10. On or about March 17, 2014, Reliable Finance Co, LLC assigned the Note to Dynamic Legal Recovery, which assignment is attached hereto, made a part hereof and is marked Exhibit 3. 11. Judgment has not been entered previously on the Note in any jurisdiction. 12. Defendants defaulted on the Note by failing to pay it in full as the Note provides. 13. By terms of the Note, there is due Plaintiff from Defendants the following sums: Principal Balance Remaining on the Note $34,619.49 Interest at 15%per annum from March 9,2012 through May 16, 2014 11,353.30 Collection Costs 6,923.90 TOTAL $52,896.69 14. Pursuant to the terms of the Exhibit 2 Demand Note, plaintiff is entitled to interest at 15%per annum from March 9, 2012 through the date of Judgment and 15%thereafter on the judgment amount. 15. On or about April 11, 2014, defendants Erick Booz and Newburg Transport, Inc. were given notice of default and opportunity to cure. 16. On or about May 1, 2014, defendant Shannon Black was given notice of default and opportunity to cure. 17. As more formally described in the attached Exhibit 4 Affidavit of Dynamic Legal Recovery, the last payment that cleared defendant's bank was in the amount of$981.37 and was posted on August 15, 2013. 18. Based upon defendants' default on the Demand Note and failure to cure, plaintiff is entitled to confess judgment against each defendant, as set forth in the Note. WHEREFORE, plaintiff demands judgment by confession against defendants in the principal amount of$34,619.49, plus accrued interest through May 16, 2014 of$11,353.30, continuing interest at 15%per annum from May 16, 2014 t ro gh the date this judgment is paid in full, collection costs of$6,923.90, and the costs of this ctio . Burto Nei & Associates, P.C. By: e ek C. Blasker, Esquire Attorn�y for Plaintiff 1. � -... .. � ,. REUA61E FINANCE.COO?ANY LEC PO BOX 32 Uotland.'PA 17254 47171-4.77.2312 APPLI'CAT.I.ON FOR CRFDI.P Name: Newburg Transport,. lAc.-Brick- Scoz%Shannon d1ack Address: 2.S Tu;no t:e Rd./>3-3 `Goon Rd... CIt j?: St-c-31-6: TA zip:. 1-124,D/ , 12ao/ 5 0 Home Phone:- 710-423.-.57'110 C0II I?hore: ;1 1-1.29-3C�3 Social 20T-00=2560 Date .o -Wirth- 4/';/75 /.195-66-2353 6/:23/76 Ema::a. Add_ess Abnut yoor Borne: Own R.6n Other C—nec . Accz Ch :l:1RQ 'itcc% No.: Say.i'ra -Acct NO. :t:E�l.ayer: '_ears t:rt�?oyes: Annual Sa3.ax a -(3".her Sni obme: $ Etas _iv ii i :dth You.) Phbne: Address. 2. Mane; Etione.:; s;dd•r.es-s =j 41�n.n3 bai`C'w Z he_dby.cart__y _hat ';i.i k:i %r .+_:=o:n9L.lar ; :*aie p:a:.ci«r3 Sr, e.ritection �:tcn for crcd_- i:. U.10 ^.d :nr:zc:':. 21 �:ci;, zle -Pinancc is au:h•-_a'tea io •n '* +�,• ••.fn •� �, t."` RR1_,a�1^ ?i'3:.L1i'C:� 3I U, i 'G :t COV.I!jC_3iv• ?XG..'•t:t:�yt. z13i. iC '1_ _s �c__ _ st nl? .Y P. Ra_.....: n•I'L::: 'dR7 a.711:i,:n '3I ;CZt`.rt��. J. <!-r, 't0 •A}Iw :1 RCi_' .19+Fi ?3:: Q.=CGzyafiJ'.F•✓w P..[)V .:t�?�t.f�•:.. i42 A 'd. t- :'iL_S G-Ld. "i37�' :d�. � Yc7:_L�'; SCGti�7.L�1 .>^.ijS; '0 3 :�{itP+'J''•:C�1_�a !±.'. micires=. :5} 2 agree to tb.^^u-.d by. Lha ups *f .the± �eriy-4•._I�`e .if .th_s •app i•:s:i4n t• ; .. a. ter :.e�iriliia.a^ raitce .Cas aari:�.iit. t± ..ac adaL s d .a .�. . .i.2: :AAs 'F.>= My~c..pt':S:i! scsr. s r.- 1-r;- :*nracwica wiih c y b. -t-t et .:.+ c n= Arm = c-:?a:;t t }%f_.. •APPUCANT=SSIGNATURE EXHIBIT My Comma EXHIBIT cL Dynamic Legal Recovery _ v r Attorneys-Private Investigators-Commercial&Retail Litigators 23236 Lyons Ave Suite 220 Santa Clarita CA,91321 P:661-451-2220 F:855785 8648 www.yourcolledionattomey.com March,17,2014 ASSIGNMENT OF DEBT ASSIGNOR: ASSIGNEE: Reliable Finance Co LLC DYNAMIC LEGAL RECOVERY Audry Baumgardner 23236 Lyons Ave.#226 PO BOX 32 Santa Clarita,CA 91321 Scotland,.PA.17254 RE:Newburg Transport Inc. Shannon Black&Erik Booz 25.Turnpike Rd,Newburg;PA 17240 CASE REF.#:DLR-2014-0268 The undersigned does assign transfer to Dynamic Legal Recovery,(assignee)my/our claim-and demands against the above-named customer in the amount of.$34619.49(Dollars)plus interest and penalties,if any,and I/we authorize said assignee'Dynarnic Legal Recovery,to enforce payment of the same;by legal remedies or otherwise for its use and benefit,and in the event of an attachment,pursuani to my state statue. I/We authorize Dynamic Legal Recovery to institute litigation in the name of Dynamic Legal Recovery (assignee)for purposes of collecting the debt assigned as allowed bylaw. In the event that my/our aforesaid claim or demand is guaranteed,such guaranty or guaranties are also hereby transferred and set over to the assignee above-named. WITNESS my/our hands the date above written. Signature: eliable Financ o LLC Print Nade e and Title 23236 Lyons Ave Suite 220 Santa Clarita CA 91321 P:661451-2220 F:855-785-8648 www.yourcollectionattbmey.com XHEIBIT Burton Neil &Associates,P.C. Derek C. Blasker,Esquire ID.NO. 202150 1060 Andrew Drive, Suite 170 West Chester,PA 19380 610-696-2120 Attorney for: Plaintiff DYNAMIC LEGAL RECOVERY assignee : IN THE COURT OF COMMON PLEAS of RELIABLE FINANCE COMPANY LLC Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA v. NO. NEWBURG TRANSPORT,INC. ✓ and SHANNON BLACK AND ERICK BOOZ Defendants :IN CONFESSION OF JUDGMENT Affidavit of Default Mkv&� ,,�C a� ,being duly sworn according to law, deposes and says: L I,� D,,,,,,Jamthe V.f for plaintiff in the above-captioned action in the Cumberland County Court of Common Pleas; 2. That defendants are in default of the terms of the Demand Note executed by the parties, a true and correct copy of the Demand Note is attached to the Complaint; 3. That defendants have made payments totaling$6,632.10 toward the Principal Amount set forth in the Demand Note; 4. That defendants'last payment was made on or about August 15, 2013; 5. Upon information and belief defendants'were advised of their default and were given an opportunity to cure; 6. As of the date of this Affidavit, defendants have not cured the default; 7. That this Affidavit is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Ze��� DATED: ` affiant EAHIBIT Verification DI, ,,/ ArJ am the V`P &C-PAi`7DIVf) [title/position] for Dynamic Legal Recovery the plaintiff. I verify that the statements of fact in the within pleading are true and correct to my knowledge, information and belief. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904,relating to unsworn falsification to authorities. Date: " LY 175135 U 61D VA /cou 1! r Burton Neil &Associates, P.C. Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for: Plaintiff DYNAMIC LEGAL RECOVERY assignee IN THE COURT OF COMMON PLEAS of RELIABLE FINANCE COMPANY LLC 23236 Lyons Avenue #220 Santa Clarita, California 91321 Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. NEWBURG TRANSPORT, INC. 25 Turnpike Road Newburg, Pennsylvania 17240 and SHANNON BLACK 25 Turnpike Road Newburg, Pennsylvania 17240 AND ERICK BOOZ 233 Booz Road Shippensburg, Pennsylvania Defendant : IN CONFESSION OF JUDGMENT Certification of Address Understanding that false statements herein are s ject to penalty under 18 Pa.C.S.Section 4904 relating to unsworn falsification to authorities, I ve ify that the above are the precise last-known addresses of the judgment creditor and debtor. BURT IL & ASSOCIATES, P.C. By: D r . Blasker, Esquire Attorne for Plaintiff BURTON NEIL & ASSOCIATES, P.C. By: Derek Blasker, Esquire, Id. No. 202150 ;,u/'QE�? � WesOAnt Chester, PA 193drew Drive, gpte 170 F ,�S v t Cot' !' 610-696-2120 Attorney for Plaintiff DYNAMIC LEGAL RECOVERY assignee IN THE COURT OF COMMON PLEAS of RELIABLE FINANCE COMPANY LLC Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. )q.' 3ab 01�1 NEWBURG TRANSPORT, INC. and SHANNON BLACK AND ERICK BOOZ Defendants : IN CONFESSION OF JUDGMENT Affidavit of Non Military Understanding that false statements herein are subject to penalty under 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, I verify that pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA) the defendants are not in the military service of the United States based on information received fro t e defendants and/or the Department of Defense website. BURT IL & ASSOCIATES, P.C. By: De Blasker, Esquire Attorne for Plaintiff Burton Neil & Associates, P.C. Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for: Plaintiff DYNAMIC LEGAL RECOVERY assignee IN THE COURT OF COMMON PLEAS of RELIABLE FINANCE COMPANY LLC Plaintiff CUMBERLAND COUNTY, PENNS LVANIA h V. . NO. q.,'3 NEWBURG TRANSPORT, INC. and SHANNON BLACK AND ERICK BOOZ Defendants : IN CONFESSION OF JUDGMENT Rule of Civil Procedure No. 236 (Revised) Notice is given that a judgment in the above captioned matter has been entered against you on Prothonotary By: .. Deputy ; If you have any questions concerning the above, please contact: Derek C. Blasker, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 193802 610-696-2120 RELIABLE FINANCE COMPANY LLC f)EMAND.NOTE PO Box 32 Scotland.,PA V72-54. 1-717-47.7-2312 Amount Borrowed by Debtor: Datc of Vote: $412251.59 J4arch 9,20 t 2 Namc \rcwbtirt:.'l*r.im ort. Inc.-t rick..E3oozlShannon Black;: 25 Turttpik Roaib12.33 L3o6z.Road Nlailing Address �ewbuEgI-ghippensburg PA 17240!17257 Cih State. Zip Jointly and scwralls,promise to pa; to•tht order:of 1kcliabte,,11tance•Company LLC•PO Rqr.i2,Sebtlind PA 17254;1hc sum of S11.25t.�9 tFUK'I'1`OAF. t H USANf)TtiO Hl3tiUliEU::FiFT\'-()`E tJUl:1 ARS;AND tiFTY..N'*I�I CEftiT'Sl%�-ith interest in the amuwtt of 15%; and %�hhoui defatistion for�aliie reccivW_and IVc do hereby authorize the Prothonotat}or any anomey of any court of mcurd in Pennsylrania.or tlsew'here to evnfc3s.jut gment of the above sum%Yi h cosi of suit:and.attonwyS IccS..for collection,and without stav-of,executiomnnd do waivt'the-.right and;lxnrftt of ani lash of this oc ttny tither Stott eXtmptin� t propeny.,rtial or personal..tilt sale. aittl if lc.vv .is trade On land. so also waive the•i•igFit of inquisition. i,titi consent to the. condemnation thereof;and au06671e tlw.yalc of d same on a sprit of execution,with rut.-ase Of errors therein attd all defenses to this. nate.also hereby i*is•c to the hold&hetiof a security int��st for.thramount of all the foregoing obligation and do.htrtby:authoA;,e the.hyl&r,at 'his option.to apply to the payment of.,such gbligittion am-and all monies note or tiereafter.in.the hands of the holder on deixicit ctr otherstjse.belonging to the ti dcrsigtitd;and'or any of them.�whethei cuch.obligioit be then due or not. In wisfaction.ot'the above monies.Reliable.Finance.LLC agres to aceept•installment payments in the:ainount:ofS981.37 per month Aw S1\TY�(60)Ton 13eginittrig.lpril 14.2012:due and'paYablc.on tach'mcmlhl)'anttiYlrsttry'of the date wtitten above. Total Amount of Note S58.882-35(Includes:pRnciplvand•interestl. Wimess m?•,otic hand and seal,the.day'and;ycar first written above. F:rtck 13 htur!t tee Dkbtor- `at , Shannon Stack-Debter Si_natur> Debtor-Print Dame. Reliabte.finance Company LLC:si cure NOTARY I.AL: On this�„day of ,2012,be#are rtie;tete urxiersigFipd pfftcer;-personalty appeared. s l h r:.. 31 a.c.l�•.- - knoym tome(or.sattsfactority or6ven)to be tha peison.whose:itarlie issubscribed_to fhe above iitstrtlirterit,and,acttita de*0 that hefshe executed the some.for•the purposes therein contained: H t 1A, tN W1Tt�ES , $ a _ artd official seat: t>� My Comm' otary Pilblic: .�� .=•. �-�• EXUH1 B I T �L 175135 / 232 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 DYNAMIC LEGAL RECOVERY Assignee of : IN THE COURT OF COMMON PLEAS RELIABLE FINANCE COMPANY LLC Plaintiff v. NEWBURG TRANSPORT, INC. AND SHANNON BLACK AND ERICK BOOZ Defendant(s) and MEMBERS FIRST FCU Garnishee(s) 2 1• rrn To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTE r— : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-3086 Civil : CIVIL ACTION - LAW 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against NEWBURG TRANSPORT, INC. AND SHANNON BLACK ERICK BOOZ 3. and against 4. and index this writ , Defendant(s) —4 MEMBERS FIRST FCU , Garnishee(s) c_.. (a) against Defendant(s) (b) against Garnishee(s) as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (specifically describe property) Levy on property of the defendants as follows: Newburg Trasnport and Shannon Black c/o 25 Turnpike Road, Newburg PA 17240 Erick Booz c/o 233 Booz Road, Shippensb .. •, PA 17257 Serve interrogatories on garnishee at: 1000 B awr Road, Carlisle PA 17013-1588 5. Amount Due $52,896.69 Interest from 05/22/2014 $365.52 Total $53,262.21* *Plus writ costs Dated: July 3, 2014 I- D��i Blasker, Esquire Attorne for Plaintiff a 0. c i c pDNOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. Baas .1830( DI6c, 775sired 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 DYNAMIC LEGAL RECOVERY ASSIGNEE OF RELIABLE FINANCE COMPANY LLC Vs. NO 14-3086 Civil Term CIVIL ACTION — LAW NEWBURG TRANSPORT, INC. AND SHANNON BLACK AND ERICK BOOZ WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against NEWBURG TRANSPORT, INC. AND SHANNON BLACK, 25 TURNPIKE ROAD, NEWBURG, PA 17240 AND ERICK BOOZ, 233 BOOZ ROAD, SHIPPENSBURG, PA 17257 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; LEVY ON PROPERTY OF THE DEFENDANTS AS FOLLOWS: NEWBURG TRANSPORT, INC. AND SHANNON BLACK, 25 TURNPIKE ROAD, NEWBURG, PA 17240 AND ERICK BOOZ, 233 BOOZ ROAD, SHIPPENSBURG, PA 17257 . (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS FIRST FCUGARNISHEE(S), as garnishee, 1000 BRYN MAWR 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. 1 (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 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 $52,896.69 Plaintiff Paid Interest FROM 5/22/2014 - $365.52 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $75.00 Other Costs Date: 07/10/14 (Seal) David D. Buell, Prothonotary REQUESTING PARTY: Name : DEREK C. BLASKER, ESQUIRE Address: LAW OFFICES OF BURTON NEIL & ASSOCIATES, P.C. 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. 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 n C SHERIFF'S OFFICE OF CUMBERLAND COUNTY ro xrn2 Ronny R Anderson Sheriff � ci) -<D p. : Di Ea)n6rrr4,„d 1—Z' Jody S Smith ` Cd Chief Deputy v c) Richard W Stewart ! D Solicitor oFFicE of THE SHERIFF —4 •-G Dynamic Legal Recovery Assignee of Reliable Finance Company LLC vs. Newburg Transport, Inc. (et al.) Case Number 2014-3086 SHERIFF'S RETURN OF SERVICE 07/30/2014 01:30 PM - William Cline, 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, 1166 Walnut Bottom Road, Carlisle, PA 17013, Cumberland County, by handing to Meg Beaston, Member Services Rep., personally nine copies of interrogatories together with nine true and attested copies of the Writ of Execution a d made the contents there of known to her. August 01, 2014 {c) CountySulto Sheriff, Teleosoft, Inc. AM INE, DEPUTY SO ANSWERS, RONIV ANDERSON, SHERIFF RECEIVED Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 AUG 01 2014 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff DYNAMIC LEGAL RECOVERY Assignee of : IN THE COURT OF COMMON PLEAS RELIABLE FINANCE COMPANY LLC Plaintiff v. NEWBURG TRANSPORT, INC. AND SHANNON BLACK 25 Turnpike Road, Newburg PA 17240 AND ERICK BOOZ 233 Booz Road, Shippensburg, PA Defendant(s) MEMBERS FIRST FCU Garnishee : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-3086 Civil : CIVIL ACTION -LAW To: MEMBERS FIRST FCU 1000 Bryn Mawr Road, Carlisle PA 17013-1588 anSitier5. Interrogatories to Garnishee You are required to file answers to the following interrogatories withing twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant or any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant 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 other persons any property of any nature owed solely or in part by the defendant? _S. 3. If the answer to 1 and/or 2 is yes, please specify the nature of the property and, if money, the amount? . F c- \ c e.. ,oA rc\ \ .� o A ok-c.._C_c71..Li 4. 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 defendant held or claimed any interest? �� �� RECEIVED AUG 01 2014 5. At the time you were served or at any subsequent time did you hold as fiduciary any property in which defendant had an interest? 1Nc 6. At any time after you were served did the defendant transfer or deliver any property to you or any person or place pursuant to your direction or consent and if so what was the consideration therefor? 7. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? 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 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 and the entity electronically depositing those funds on a recurring basis. 9. 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 funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. C\ec_\h\ r q � Burton Bv: Der Associates, P.C. C. Blasker, Esquire This is an attempt to collect a debt, and any information obtained will be used for that purpose. This communication is from a debt collector. RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy c°otp of eurrrbett� OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 Dynamic Legal Recovery, assignee Of Reliable Finance Company, LLC VS Newburg Transport, Inc. and Shannon Black and Erick Booz To Whom It May Concern: October 13, 2014 RICHARD W. STEWART Solicitor r 400 rrict)r- -4-4 '0 rti 27' Q n r, In the Court of Common Pleas y Cumberland County,. Pennsylvania --r. o • -.311 CP Writ of Execution No. 2014-3086 Property Claim Determination Reference is made to Property Claim filed October 2, 2014, entered by Hope Alspaugh, Cumberland County Writ No. 2014-3086, Dynamic Legal Recovery, assignee of Reliable Finance Company, LLC vs Newburg Transport, Inc., and Shannon Black and Erick Booz. Ronny R. Anderson, Sheriff, has determined that the claimant, Hope Alspaugh, in the above mentioned property claim, is the owner of the property set forth in the claim. So Ans : s: . Anderson, Sheriff By cc Hope Alspaugh, Claimant Newburg Transport, Inc., Defendant Erick Booz, Defendant Shannon Black, Defendant Derek C. Blasker, Attorney for Plaintiff NOTICE OF PROPERTY CLAIM Dynamic Legal Recovery, assignee Of Reliable Finance Company, LLC VS Newburg Transport, Inc. and Shannon Black and Erick Booz In the Court of Common Pleas ' Cumberland County, Pennsylvania Writ of Execution No. 2014-3086 TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Hope Alspaugh, claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 10/03/2014 Cc Hope Alspaugh, Claimant Newburg Transport, Inc., Defendant Erick Booz, Defendant Shannon Black, Defendant Derek C. Blasker, Attorney for Plaintiff of Cumberland County By PROPERTY CLAIM DYNAMIC LEGAL RECOVERY, assignee of RELIABLE FINANCE COMPANY, LLC vs. NEWBURG TRANSPORT, INC. and SHANNON BLACK and ERICK BOOZ In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No: 14-3086 TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE Any and all real and personal property located at 222 E. Orange Street, Shippensburg, Pennsylvania ' /SIS, £GL'). Any and all funds in Members 1" Federal Credit Union Account ending - 341195 .0 53i1,i'I THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: Property listed above is joint property and/or purchased with joint funds thereby conveying an interest to the undersigned claimant. Date: ) 0) Z .)) 1f Claimant: 1,-4 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND pt Akpa &L that the above list in the property claim are correct and true. ,bpo.kLe being duly sworn according to law, deposes and says Sworn and subscribe tobeforeme This c9 / day of [ CID /)L� 00l ) S_AtiotitoL j1L1 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shannon L Freeman, Notary Public Carlisle Boro, Cumberland County My Commission Expires April 7, 2017 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES CFP -CL:-.) IIbDOU - Claiman i aaa cle> etd RcL fns f ?A na51 Lin) 5.30-151 RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy coo Orurrthely OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 October 13, 2014 Dynamic Legal Recovery, assignee Of Reliable Finance Company, LLC VS Newburg Transport, Inc. and Shannon Black and Erick Booz Property Claim Determination To Whom It May Concern: In the Court of Common Pleas Cumberland County, Pennsylvania Writ of Execution No. 2014-3086 RICHARD W. STEWART Solicitor Reference is made to Property Claim filed October 2, 2014, entered by Kelly Booz, Cumberland County Writ No. 2014-3086, Dynamic Legal Recovery, assignee of Reliable Finance Company, LLC vs Newburg Transport, Inc., and Shannon Black and Erick Booz. Ronny R. Anderson, Sheriff, has determined that the claimant, Kelly Booz; in the above mentioned property claim, is the owner of the property set forth in the claim with the exception of the Dodge Ram Truck, which is registered solely to Erick Booz. So Answers: cc Kelly Booz, Claimant Newburg Transport, Inc., Defendant Erick Booz, Defendant Shannon Black, Defendant Derek C. Blasker, Attorney for Plaintiff NOTICE OF PROPERTY CLAIM Dynamic Legal Recovery, assignee Of Reliable Finance Company, LLC VS Newburg Transport, Inc. and Shannon Black and Erick Booz In the Court of Common Pleas Cumberland County, Pennsylvania Writ of Execution No. 2014-3086 TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Kelly Booz, claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 10/03/2014 Cc Kelly Booz, Claimant Newburg Transport, Inc., Defendant Erick Booz, Defendant Shannon Black, Defendant Derek C. Blasker, Attorney for Plaintiff PROPERTY CLAIM DYNAMIC LEGAL RECOVERY, assignee of RELIABLE FINANCE COMPANY, LLC VS. NEWBURG TRANSPORT, INC. and SHANNON BLACK and ERICK BOOZ In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No: 14-3086 TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE Smith & Wesson; Model SW9VE; 9mm $200.00 Winchester; Model 270; .22 caliber $200.00 Kitchen Table and 8 chairs $300.00 Coffee pot $5.00 Electrolux Refrigerator $800.00 Built -In Stove $150.00 Black & Decker Toaster $30.00 Kitchen utensils $100.00 Pots/Pans $50.00 Crock -pot $30.00 Buffet $200.00 Samsung Washer $150.00 Samsung Dryer $150.00 Grandfather clock $400.00 Bookshelf $50.00 Rolltop Desk $100.00 Wooden file cabinet $50.00 Patio Furniture $300.00 King Bed $100.00 Samsung television $75.00 Armoire $150.00 Standing mirror $50.00 Samsung blu-ray $25.00 GE Air Conditioner $30.00 Cadillac; Vin # 1GYFK66858R214035 $30,000.00 Chevy; Vin # 1GCRKSE35BZ284627 $20,000.00 Dodge; Vin # 3B7HF13Z8XG212877 $2,500.00 Baldor Generator $500.00 Tool Box and miscellaneous tools $300.00 Samsung Refrigerator $600.00 Lawn tools $100.00 2 — Frigidaire Freezers $650.00 Ladder $100.00 Table saw $75.00 John Deere riding mower $500.00 Snowblower $600.00 Wooden book rack $50.00 Wooden radio $20.00 White mini -fridge $25.00 Black leather massage chair $5,000.00 Brown couch $300.00 Brown recliner with ottoman $150.00 LG flat screen television $100.00 Wooden entertainment center with built-in fireplace $300.00 2 — Wooden bookshelves in garage $10.00 Small plastic pet carrier $5.00 Oreck vacuum $100.00 Shark vacuum $10.00 Dresser in garage $50.00 Black chest in garage $30.00 Perfect flame grill $300.00 Brown hot tub $4,000.00 Any and all real and personal property located at 25 Turnpike Road, Newburg, Pennsylvania THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: Property listed above is marital property and/or purchased with marital funds thereby conveying an interest to the undersigned claimant. Date: Claimant: STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND Po©Z that the above list in the property claim are correct and true. being duly sworn according to law, depos s and says Sworn and subscribed to before me This a nd day of DCivbex' cbl� teig-#71.0.4)otary Public Cla ' ant �5 I t�rn�i Ro (1Li)&-0160, RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy To Whom It May Concern: ox‘vttp Dieu h et, OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 RICHARD W. STEWART Solicitor.:: �.w r— =C 7(f November 24, 2014 =,- ti Dynamic Legal Recovery, assignee of Reliable Finance Company, LLC vs Newburg Transport, Inc., and Shannon Black and Erick Booz Writ No. 2014-3086 Property Claim Determination Reference is made to Property Claim dated November 12, 2014, entered by Ciera Booz, Cumberland County Writ No. 2014-3086, Dynamic Legal Recovery, assignee of Reliable Finance Company, LLC vs Newburg Transport, Inc., and Shannon Black and Erick Booz. Ronny R. Anderson, Sheriff, has determined that the claimant, Ciera Booz, in the above mentioned property claim, is not the owner of the property set forth in the claim, as the Dodge Ram truck is registered solely to Erick Booz. (}l '_ cc Ciera Booz, Claimant Newburg Transport, Inc., Defendant Shannon Black, Defendant Erick Booz, Defendant Derek C. Blasker, Attorney for Plaintiff NOTICE OF PROPERTY CLAIM Dynamic Legal Recovery, assignee Of Reliable Finance Company, LLC VS Newburg Transport, Inc. and Shannon Black and Erick Booz In the Court of Common Pleas Cumberland County, Pennsylvania Writ of Execution No. 2014-3086 TO THE DEFENDANTS AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Ciera Booz, claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 11-12-2014 Cc Ciera Booz, Claimant Newburg Transport, Inc., Defendant Shannon Black, Defendant Erick Booz, Defendant Derek C. Blasker, Attorney for Plaintiff se -aa„ of Cumberland County PROPERTY CLAIM DYNAMIC LEGAL RECOVERY, assignee of RELIABLE FINANCE COMPANY, LLC vs. NEWBURG TRANSPORT, INC. and SHANNON BLACK and ERICK BOOZ In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No: 14-3086 TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY Dodge; Vin # 3B7HF13Z8XG212877 VALUE $2,500.00 THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: Property listed above is my property and/or purchased with my personal funds thereby conveying an interest to the undersigned claimant. Date: STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND Claimant: _J jttee)t Ciera Booz 25 Turnpike Road Newburg, PA 17240-9327 (717) 2.3- 0/5". I, Ciera Booz, being duly sworn according to law, deposes and says that the above list in the property claim are correct and true. Sworn an subscribed to before me This II {�' day of Id a VQ b e D)Li- Claimant SiO,a-tIVJA, (7e- itteilia-ft—i Ear: v Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shannon L. Freeman, Notary Public Carlisle Boro, Cumberland County My Commission Expires April 7, 2017 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 0