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HomeMy WebLinkAbout14-3761 Supreme Cou. o Pennsylvania Cour o �Co o leas For Prothonotary Use Only: N eel �v Docket No: I� � 1 1 Cu .`IER' Ll�ldi " ` County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S [0 Complaint 0 Writ of Summons ❑� Petition Q Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: ALLY FINANCIAL INC. CORA E. HOSTETLER T I Are money damages requested? CD Yes D No (check one) Owithin arbitration limits Dollar Amount Requested: i 0 Doutside arbitration limits N Is this a Class Action Suit? Fil Yes El No Is this an MDJAppeal? ( Yes C@ No A Name of Plaintiff/Appellant's Attorney: Joshua D. Bonn, Esquire 0 Check here if you have no attorney(are a Self-Represented [Pro Sel :Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately 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 Intentional Buyer Plaintiff Administrative Agencies Malicious Prosecution 0 Debt Collection:Credit Card Board of Assessment 0 Motor Vehicle 0 Debt Collection:Other 0 Board of Elections 0 Nuisance 0 Dept.of Transportation F-1 Premises Liability [] Statutory Appeal:Other S 0 Product Liability (does not include 0 Employment Dispute: mass tort) E M Slander/Libel/Defamation Discrimination C 0 Other: Employment Dispute:Other El Zoning Board T Other: I Other: O MASS TORT 0 Asbestos N Q Tobacco 0 Toxic Tort-DES [3 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS M Toxic Waste 0 Ejectment iJ Common Law/Statutory Arbitration B 0 Other: 0 Eminent Domain/Condemnation 0 Declaratory Judgment 0 Ground Rent EMandamus 0 Landlord/Tenant Dispute E]Non-Domestic Relations Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY n Mortgage Foreclosure:Commercial 0 Quo Warranto Dental 0 Partition 0 Replevin 0 Legal E] Quiet Title Other: Medical Other: "Count of Replevin is not 0 Other Professional: su lect to ar itration Updated 1/1/2011 r NAUMAN, SMITH, SHISSLER& HALL, LLP ��'`'=1fa'r� Stephen ire S c��';" Supreme Court I.D.I.D24580 sT<" Joshua D. Bonn, Esquire Supreme Court I.D. No. 93967 200 N. 3rd Street, 18th Floor Counsel For: Ally Financial Inc. P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 ALLY FINANCIAL INC., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PA • V. !� . NO. CORA E. HOSTETLER, CIVIL ACTION ADAM E. HUMMEL, Defendants ACTION IN REPLEVIN 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 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, 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 S. Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 (800) 990-9108 , d Q �1 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por aboado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende,la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO,ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER 1NFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 (800) 990-9108 NAUMAN,SMITH,SHISSLER&HALL,LLP J. Stephen Feinour, Esquire Supreme Court I.D. 24580 Joshua D. Bonn,Esquire Supreme Court I.D. No. 93967 200 N. 3`d Street, 18"Floor P. O. Box 840 Harrisburg PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: Ally Financial Inc. Dated: June 24, 2014 NAUMAN, SMITH, SHISSLER& HALL, LLP J. Stephen Feinour, Esquire Supreme Court I.D. 24580 Joshua D. Bonn, Esquire Supreme Court I.D. No. 93967 200 N. 3rd Street, 18th Floor Counsel For: Ally Financial Inc. P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 ALLY FINANCIAL INC. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PA CIVIL ACTION V. . NO. CORA E. HOSTETLER, ADAM E. HUMMEL, Defendants : ACTION IN REPLEVIN COMPLAINT AND NOW comes Plaintiff,Ally Financial Inc.,by its counsel,Nauman, Smith, Shissler& Hall, LLP, to file the within Complaint based upon the following facts: 1. Ally Financial Inc. (hereinafter"Ally Financial")is a entity organized under the laws of Delaware having offices throughout the United States and having an office at 2740 Arthur Street, Roseville, MN 55113. 2. Cora E.Hostetler(hereinafter"Defendants")is an adult individual presently residing at 165 Lee Ann Ct., Enola, PA 17025. 3. Adam E.Hummel(hereinafter"Defendants")is an adult individual presently residing at 9115 Ridgefell Avenue, Pittsburgh, PA 15237. COUNT ONE REPLEVIN 4. On July 23,2013,Defendants entered into an Agreement of Lease with Ally Financial fora 2013 Chevrolet Cruze with Vehicle Identification Number 1 G1 PA5 SG2D7318372(hereinafter the Agreement of Lease is referred to as "Lease"). A copy of the Lease is marked as Exhibit "A", attached hereto and its contents are incorporated herein by reference. 5. Defendants, pursuant to the aforesaid Lease, agreed, inter alia, to make thirty-nine (39) monthly lease payments in an amount of Two Hundred Thirty-Seven and 63/100 Dollars ($237.63) each commencing on July 23, 2013, payable on the day of each successive month thereafter,with one(1)final payment,if chosen by Defendants to purchase the vehicle,in the amount of Thirteen Thousand Six Hundred Fifty-Two and 40/100 Dollars($13,652.40).(See,e.g.,Lease at ¶¶2,9; Exhibit "A"hereto.) 6. Under the Lease,Ally Financial retained legal ownership and title to the vehicle. A copy of an Electronic Title Document is marked Exhibit"B",attached hereto and made a part hereof by reference. 7. Defendants,pursuant to the aforesaid Lease,agreed that in the event of default in any payment due under the Lease, or the failure to comply with any term or condition thereof,that Ally Financial may take immediate possession of said property,including any equipment or accessories thereto, and for this purpose Ally Financial may, in any lawful manner, enter upon the premises where the said property may be and remove same. (See, e.g., Lease at¶ 37; Exhibit"A"hereto.) 2 8. Under the terms of the aforesaid Lease, Defendants agreed that in the event they defaulted in any payment due thereunder,or failed to comply with any of the terms or conditions of the Lease, and in the event it became necessary for the Lessor or its assignees to institute a suit in replevin for the Vehicle,Defendants agreed to pay all costs of suit and any reasonable attorney's fees. (See, e.g., Lease at¶ 37; Exhibit"A"hereto.) 9. Defendants have breached the said Lease,in that Defendants have failed to make the agreed-upon lease payments due. 10. Such defaults are continuing. 11. The present outstanding balance due Ally Financial from Defendant as of May 22, 2014, is in the amount of Seventeen Thousand Five Hundred Thirty-Six and 44/100 Dollars ($17,536.44), plus costs. 12. Ally Financial sent Defendants Notices of Default by letters dated May 7, 2014. A true and correct copy of said Notices of Default are attached hereto as Exhibit"C" and incorporated herein by reference. 13. Defendants have failed to cure the default under the Lease. 14. Ally Financial has made repeated demands that Defendants make the payments agreed upon, all to no avail. 15. The aforesaid vehicle is presently in the control and custody of Cora E.Hostetler, 165 Lee Ann Ct., Enola, PA 17015 and/or Adam E. Hummel, 9115 Ridgefell Avenue, Pittsburgh, PA 15237. 3 16. Vehicles of this model and class have an average value of Thirteen Thousand Two Hundred Seventy-Five and 00/100 Dollars ($13,275.00). WHEREFORE,Ally Financial Inc.prays that this Honorable Court enter judgment in favor of Ally Financial Inc. and against the Defendants,jointly and severally, for: i. Possession of the 2013 Chevrolet Cruze with Vehicle Identification Number 1G1PA5SG2D7318372 or the alternative, the market value of the car in the amount of Thirteen Thousand Two Hundred Seventy-Five and 00/100 Dollars ($13,275.00); and ii. Reasonable attorney's fees and legal expenses incurred by reason of the institution of this action in replevin to repossess the aforementioned vehicle; all as agreed to in the Lease dated July 23, 2013. COUNT II BREACH OF CONTRACT 17. Paragraphs 1 through 16 above are incorporated herein by reference. 18. Pursuant to the Lease, Defendants have defaulted by their failure and refusal to pay lease payments in arrears, the sum of which (including late fees and unpaid charges) is One Thousand Five Hundred Five and 75/100 Dollars ($1,505.75) Dollars as of June 16, 2014, and increasing monthly. 19. At all times material to this case,Ally Financial has fully and satisfactorily conformed to and complied with all terms and conditions required of it under the Lease. 4 20. Pursuant to the Lease, Defendants' default entitled Ally Financial to lease payments in arrears, a late fee equal to 5% of the total amount of arrears, plus all other costs incurred in connection therewith. 21. The present outstanding balance due Ally Financial from Defendant as of May 22, 2014, is in the amount of Seventeen Thousand Five Hundred Thirty-Six and 44/100 Dollars ($17,536.44),plus costs. 22. The Lease provides that in the event the Defendants did not make the agreed upon monthly payments,resulting in a default under the Lease,and Ally Financial was required to employ an attorney,the Defendants agreed to pay reasonable attorney fees and Court costs. (See,e.g.,Lease at¶ 37; Exhibit"A"hereto.) WHEREFORE, Ally Financial Inc. demands judgment in its favor and against the Defendants,jointly and severally, for: a. The sum of Seventeen Thousand Five Hundred Thirty-Six and 44/100 Dollars ($17,536.44),plus a late fee equal to 5%of the total amount of arrears,and all other costs incurred in connection therewith; and b. Reasonable Attorney's fees and legal expenses incurred in connection with installments in arrears; and C. Any and all other relief which this court deems appropriate. 5 NAUMAN,SMITH,SHISSLER&HALL,LLP Stephen Feinour, Esquire Supreme Court I.D. 24580 Joshua D. Bonn, Esquire Supreme Court I.D. No. 93967 200 N. 3`d Street, 18`h Floor P. O. Box 840 Harrisburg PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: Ally Financial Inc. Dated: June 24, 2014 6 VERIFICATION I.Joanne Roques,Replevin Specialist for Ally Financial Inc.,being duly authorized to do so on behalf of Ally Financial Inc.do hereby make the following statements subject to the penalties of 1.8 Pa.C.S. §4904,relating to unsworn falsifications to authority,and do state that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge,information and belief. Joanne kpues Replevin Specialist for Ally Financial Inc. 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Si it ed I ! g II f t g Yt lit 1 Edi it 5e, 3$ , .. oDi,A. et��ct3taeitiax�,taftf .�eDe.i�;t�e, ���$I,N� e�i�s. ally PO Box 380902 Bloomington,MN 55438 Jul 31, 2013 SUTLIFF CHEVROLET CO. Attention: F& I Manager 1251 PAXTON ST HARRISBURG, Pennsylvania 17104 Buyer. Cora E Hostetler Vehicle: New Chevrolet Cruze Account Number: Application Number. 1018460107 PDN: 0000061002 Thank you for submitting the lease agreement indicated above for consideration. The assignment section of this agreement was not properly completed. This letter serves as confirmation of your intention to assign the agreement as indicated below. We are sending this confirmation to avid returning the agreement to you in an effort to expedite its processing. If information in this letter is incorrect, please notify us immediately. The lease agreement listed above should have been assigned to: ALLY FINANCIAL VIN# 1G1PA5SG2D7318372 We need to do all we can to ensure disclosures are accurate on lease transactions. We ask you to review this matter with the responsible parties at your dealership and implement whatever corrective measures are needed to avoid similar issues in the future. Please let us know if we can help you in implementing any necessary changes. If you have any questions, please contact our office at 866-510-8907. Sincerely, Ally Financial Title Administration-Electronic Title Document Page 1 of 1 allyElectronic Title Document . ELT*PA Title# : 72293734 Title Type : Issue Date: 00/00/0000 Lic/Tag/Control# .. .__ .. _.. .. . VIN: 1G1PA5SG2D7318372 Vehicle Info: 2013 CHEV CZL Brand code: Odometer Reading: 000005 Date: 00/00/0000 Status: Owner information ----_..__._.....---_.._....._._.__..___..._.._._._.._ ... _._.._...__....._._.._ .. Owner Information: VAULT TRUST LSR Co-Owner: HOSTETLER,CORA E LSE Third Owner: Owner Address: 10909 MCCORMICK RD HUNT VALLEY,MD 21031 Lienholder information Lienhdlder: ALLY FINANCIAL 2nd Lienholder Name: ELT Sent Date: 00/00/0000 Lien Type: Owner Driver License#: PDP Doc Ref: 50000037115/00050 05/07/2014 09:52:09 Nam Terms of Use• Copriaht Notice• P.rivacy Policy ©2002-2014 PDP Group,Inc.All rights reserved. https://nexus.pdptechnologies.com/pdp/tts/TTS0001R.pgm?task--DAAGE&wnDocNbr-000... 5/7/2014 • Attorneys At Law _. Please reply to Joshua D. Bonn, Esquire P. 0. Box 840 JbonnCnssh.com Harrisburg, PA 17108-0840 Telephone Extension # 26 May 7,2014 Via Certified Mail No.70110470 0002 7995 6411 and Regular Mail Cora E. Hostetler 165 Lee Ann Ct. Enola,PA 17025 In re: Ally Financial Inc.Account 2013 Chevrolet Cruze Dear Ms.Hostetler: Please be advised this office represents Ally Financial Inc.(herein after"Ally Financial")and in that connection,your overdue and delinquent account has been referred to this firm for advice and the appropriate action if not resolved promptly. This letter is an attempt by Ally Financial to collect a debt,and any information obtained from this letter will be used for that purpose. Ally Financial has advised you that under the terms of a Lease Agreement,you are delinquent in paying the December 2012 payment in the amount of$170.52 and the January,February,March and April 2014 payments in the amount of$237.63 each, plus late charges in the amount of$83.16, for a total delinquency of$1,204.20. Unless you dispute the validity of the debt described above within days(30)days of the date of this letter,we will assume that the debt is valid. If you notify us within days(30)days that the debt is disputed,we will obtain further verification of the amounts owed and mail such verification to you. Pursuant to the terms and conditions of the Lease Agreement with Ally Financial that you signed,you are hereby called upon to cure the default by paying the sum of$1,204.20 within thirty (30) days of the date of this notice. Please be advised that Ally Financial reserves the right to pursue all of its rights and remedies as indicated by the Lease Agreement,which may include the seizure and repossession of the vehicle. You are also called upon to pay the attorneys' fees incurred by Ally Financial in connection with your default. Specific information concerning these attorneys' fees will be provided to you after Ally Financial's receipt of the total delinquency. Superior analysis . Effective solutions . Since 1 871 . Nauman Smith Shissler&Hall,LLP•200 North 3rd Street, 18th Floor• Harrisburg, PA 17101 • 717.236.3010 9 fax:717.234.1925 9 www.nssh.com Cora E.Hostetler Page 2 If you fail to cure the default,Ally Financial will declare the entire amount you owe under the Lease Agreement LNEW ;DIATELY DUE AND PAYABLE. You may contact Ally Financial for the total amount due. If you wish to correspond to Ally Financial directly please contact: Ally Financial Inc. Attn:P.Vang PO Box 380906 Bloomington,MN 55438-0901 You may also call Ms.Vang at Ally Financial at 888-204-9783 Ext. 2017 If you do not dispute the validity of the debt or otherwise promptly make the delinquent payments, then, Ally Financial will exercise its remedies, including (but not limited to) filing a lawsuit against you for the repossession of the 2013 Chevrolet Cruze and for breach of contract. If Ally Financial is forced to file a lawsuit against you,it will seek payment of the entire amount you owe under the Lease Agreement. I trust you will act to pay the delinquent payments, and thus avoid the expense and embarrassment of such litigation. Respectfully yours, Joshua D.Bonn JDB/sm cc: Ally Financial Inc. • Attorneys At L`aw Please reply to Joshua D. Bonn, Esquire P. 0. Box 840 Jbonn@nssh.com Harrisburg, PA 17108-0840 Telephone Extension # 26 May 7,2014 Via Certified Mail No. 70110470 0002 7995 6404 and Regular Mail Adam E.Hummel 128 Faith Circle Carlisle,PA 17013 In re: Ally Financial Inc.Account#1- 2013 Chevrolet Cruze Dear Mr.Hummel: Please be advised this office represents Ally Financial Inc.(herein after"Ally Financial' and in that connection,your overdue and delinquent account has been referred to this firm for advice and the appropriate action if not resolved promptly. This letter is an attempt by Ally Financial to collect a debt,and any information obtained from this letter will be used for that purpose. Ally Financial has advised you that under the terms of a Lease Agreement,you are delinquent in paying the December 2012 payment in the amount of$170.52 and the January,February,March and April 2014 payments in the amount of$237.63 each, plus late charges in the amount of$83.16, for a total delinquency of$1,204.20. Unless you dispute the validity of the debt described above within days(3 0)days of the date of this letter,we will assume that the debt is valid. If you notify us within days(30)days that the debt is disputed,we will obtain further verification of the amounts owed and mail such verification to you. Pursuant to the terms and conditions of the Lease Agreement with Ally Financial that you signed,you are hereby called upon to cure the default by paying the sum of$1,204.20 within thirty (30) days of the date of this notice. Please be advised that Ally Financial reserves the right to pursue all of its rights and remedies as indicated by the Lease Agreement,which may include the seizure and repossession of the vehicle. You are also called upon to pay the attorneys' fees incurred by Ally Financial in connection with your default. Specific information concerning these attorneys' fees will be provided to you after Ally Financial's receipt of the total delinquency. Superior analysis . Effective solutions . Since 1871 . Nauman Smith Shissler&Hall, LLP 9 200 North 3rd Street, 18th Floor•Harrisburg,PA 17101 •717.236.3010•fax:717.234.1925•www.nssh.com Adam E.Hummel Page 2 If you fail to cure the default,Ally Financial will declare the entire amount you owe under the Lease Agreement IMMEDIATELY DUE AND PAYABLE. You may contact Ally Financial for the total amount due. If you wish to correspond to Ally Financial directly please contact: Ally Financial Inc. Attn:P.Vang PO Box 380906 Bloomington,MN 55438-0901 You may also call Ms. Vang at Ally Financial at 888-204-9783 Ext.2017 If you do not dispute the validity of the debt or otherwise promptly make the delinquent payments, then, Ally Financial will exercise its remedies, including (but not limited to) filing a lawsuit against you for the repossession of the 2013 Chevrolet Cruze and for breach of contract. If Ally Financial is forced to file a lawsuit against you,it will seek payment of the entire amount you owe under the Lease Agreement. I trust you will act to pay the delinquent payments, and thus avoid the expense and embarrassment of such litigation. Respectfully yours, Aq4 6. *"" Joshua D.Bonn JDB/sm cc: Ally Financial Inc. afl 1jiv f1574 NAUMAN, SMITH, SHISSLER& HALL, LLP4'�,1 J. Stephen Feinour, Esquire I k RL./ Supreme Court I.D. 24580 L' P1y� '( 14l, jd Joshua D. Bonn, Esquire Supreme Court I.D. No. 93967 200 N. 3rd Street, 18th Floor Counsel For: Ally Financial Inc. P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 ALLY FINANCIAL INC., : IN THE COURT OF COMMON PL AS Plaintiff : CUMBERLAND COUNTY, A V. NO. '�, eS I U CORA E. HOSTETLER, CIVIL ACTION ADAM E. HUMMEL, Defendants ACTION IN REPLEVIN PRAECIPE FOR ENTRY OF APPEARANCE Please enter the appearance of J. Stephen Feinour,Esquire and Joshua D. Bonn,Esquire,as Attorneys for Ally Financial Inc., the Plaintiff in the above captioned case. NAUMAN,SMITH,SHISSLER&HALL,LLP jo- J tephen Feinour, Esquire Supreme Court I.D. 24580 Joshua D. Bonn, Esquire Supreme Court I.D. No. 93967 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: Ally Financial Inc. Dated: June 24, 2014 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY !- rLcC"()t f. iC_ PROTHONOTAR ZOR AUG 12 PM 2: 22 CUMBERLAND COUNTY PENNSYLVANIA Ally Financial Inc. vs. Cora E Hostetler (et al.) Case Number 2014-3761 SHERIFF'S RETURN OF SERVICE 06/26/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Adam E Hummel, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Complaint & Notice according to law. 07/16/2014 06:01 PM - Deputy Jamie DiMartle, 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: Cora E Hostetler at 6385 Carlisle Pike, Hampden Township, Mechanicsburg, PA 17055. kxiiO c3m E DIMARTLE, DEPUTY 07/23/2014 12:43 PM - The requested Complaint & Notice served by the Sheriff of Allegheny County upon Ned Sulger, who accepted for Adam E Hummel, at 9115 Ridgefell Avenue, Pittsburgh, PA 15237. William Mullen, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $81.25 SO ANSWERS, August 07, 2014 (c) CountySuite Sheriff, Teleosoft. Inc. }X" RON R ANDERSON, SHERIFF "Wormy R Ai derson Shea j Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY P7/ar Richard W Stewart Solicitor EXP: 07/25/2014 1 Ally Financial Inc. vs. Cora E Hostetler (et al.) Case Number 2014-3761 SERVICE COVER SHEET Service Details: Category: Civil Action - Complaint & Notice Manner: Deputize Notes: erve To Name: Primary Address: n Phone: z Alternate J Address: -J w U. Phone: EEE Attorney / Originator: a) Adam E Hummel 9115 Ridgefell Avenue Pittsburgh, PA 15237 Expires: 07/25/2014 Warrant: FinalyService: Served: Personally Adult In Charge: Relation: Date: Deputy: • Posted • Other Time: l) -`14301/ M 4 0 N HUMMEL, ADAM E Name: Joshua D. Bonn Service Attempts: Date: Time: Mileage: Deputy: Phone: 717-236-3010 Note / Special Instructions; CAA k.Ct Now, Ju execute Notarial Seal Eda Jean Woodward, Notary Public City of Pittsburgh, Allegheny County My Commission Expires May 28, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES eriifi of Cumberland oun y, ennsylvania do hereby deputize the Sheriff of Allegheny County to e documents herewith and make return thereof according to law. Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 Ronny R Anderson, Sheriff NAUMAN, SMITH, SHISSLER & HALL, LLP Joshua D. Bonn, Esquire Supreme Court I.D. No. 93967 200 N. 3rd Street, 18th Floor P. 0. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 Counsel For: Ally Financial Inc.. ALLY FINANCIAL INC., : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA ▪ .--"-- ---i V. : NO. 14-3761 Civil rn T- = r ' -u CORA E. HOSTETLER, : CIVIL ACTION - LAW cf.) -< . ADAM E. HUMMEL, CD -r1 2 Defendants : ACTION IN REPLEVIN PRAECIPE ▪ :7) TO THE PROTHONOTARY: Please enter judgment in favor of Plaintiff, Ally Financial Inc., and against Defendants, Cora E. Hostetler and Adam E. Hummel, jointly and severally, for failure to plead to the Complaint in this action within the required time. The Complaint contains a Notice to Defend within twenty (20) days from the date of service thereof. Defendant, Cora E. Hostetler was served with the Complaint on July 16, 2014, and an answer was due on or before August 5, 2014. Defendant, Adam E. Hummel was served with the Complaint on July 23, 2014, and an answer was due on or before August 12, 2014. Plaintiffprovided Defendants with a written "Important Notice" stating it's intention to file a praecipe for entry of default judgment which I certify was mailed by regular mail with Certificates of Mailing to the last known address of Cora E. Hostetler, 165 Lee Arm Ct., Enola, PA 17025 and Adam E. Hummel, 9115 Ridgefell Avenue, Pittsburgh, PA 15237 which is at least ten (10) days prior to the filing of this Praecipe. Please enter judgment pursuant to Pa.R.C.P. 1037(b), 1071 and 1084 for possession of a 2013 Chevrolet Cruze, VIN 1G1PA5SG2D7318372, and for $17,536.44, plus costs, for failure of the Defendants, Cora E. Hostetler and Adam E. Hummel, jointly and severally, to file an Answer to Plaintiff's Complaint within twenty (20) days of service thereof. NAUMAN, SMITH, SHISSLER & HALL, LLP *33.00 Po Asrti ell 31E/114 atiad7 No4iee ailed 02 -0 to,----- oshua D. Bonn, Esquire Supreme Court I.D. No. 93967 Dated: September 17, 2014 200 N. 3rd Street, 18th Floor P. 0. Box 840 Harrisburg PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: Ally Financial Inc. NAUMAN, SMITH, SHISSLER & HALL, LLP Joshua D. Bonn, Esquire Supreme Court I.D. No. 93967 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 fiLEO-0; 110E OF: THE PR0THONO FAR y 2014 SEP 1T8 API II : 57 CUMBERLAND COUNTY RMS Y. Counsel For: Ally Financial lnLVANIA ALLY FINANCIAL INC., Plaintiff v. CORA E. HOSTETLER ADAM E. HUMMEL • Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO: 14-3761 Civil • : CIVIL ACTION AT LAW • IMPORTANT NOTICE TO: CORA E. HOSTETLER AND ADAM E. HUMMEL DATE OF NOTICE: AUGUST 19, 2014 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 (10) 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 (800) 990-9108 NAUMAN, SMITH, SHISSLER AND HALL, LLP By: Date: August 19, 2014 1a Joshua D. Bonn, Esquire Supreme Court ID# 93967 200 North Third Street, 18th Floor, P.O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel for: Ally Financial Inc. CERTIFICATE OF SERVICE I hereby certify that on the date listed below I served a copy of the foregoing Notice by depositing in U.S. First Class Mail a copy of same addressed as follows: Cora E. Hostetler 165 Lee Ann Court Enola, PA 17025 Adam E. Hummel 9115 Ridgefell Avenue Pittsburgh, PA 15237 4Sheay Paralegal Paralegal to Joshua D. Bonn, Esquire Dated: August 19, 2014 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES PROVIDE FOR INSURANCE—POSTMASTER PT Receiveddaetman, Smith, Shis Attn. Sherry A. May, ;ts 1' 200 N. 'third Street, THarrighirrg, PA 1710 _ ® 1P OC173965L 7fA ED FROM One ,�,piece of ordinary mail addressed to: 11 Al -k P4- no.) -S' PS Form 3817, Mar. 1989 U S POSTAL SERVICE CERTIFICATE OF MAILING Affix fee here in stamps or meter postage and post mark. Inquire of Postmaster for current immazaw PITNEY BOWES $ 001.30° Affix fee here in stamps or meter postage and MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES PI p post mark. Inquire of Q Postmaster for current riffassalarenw PITNEY BOMBS PROVIDE FOR INSURANCE—POSTMASTER Received From: Nauman,, Smith, Shis Attn. Sherry A May, 200 N. Third Street, Harrisburg, FA 1710 02 1P 040173965� $ 001.30° 14 0 One piece f ordinary mail addressed to: 9Ji cL P , PS Form 3817, Mar. 1989 Please reply to: P. O. Box 840 Harrisburg, PA 17108-0840 Cora E. Hostetler 165 Lee Ann Ct. Enola, PA 17025 Joshua D. Bonn, Esquire JBonn@nssh.com T: (717) 236-3010 ext. 26 August 19, 2014 Adam E. Hummel 9115 Ridgefell Avenue Pittsburgh, PA 15237 RE: Ally Financial Inc. v. Cora E. Hostetler and Adam E. Hummel No. 14-3761 Civil Our File No.: 9768-1777 Dear Ms. Hostetler & Mr. Hummel: Enclosed herewith is our Notice to you that you are in default because you have failed to take action in the above -captioned matter. Unless action is taken within ten (10) days, we will file with the Prothonotary of Allegheny County our Praecipe to Enter Judgment. Sincerely yours, IL12.__ Joshua D. Bonn JDB/sm Enclosure cc: Ally Financial Inc. Superior analysis. Effective solutions. Since 1871. man Smith Shissler & Hall, LLP• 200 North 3rd Street. 18th Floor • Harrisburg, PA 17101 • 717.236_Ro1A- NAUMAN, SMITH, SHISSLER & HALL, LLP Joshua D. Bonn, Esquire Supreme Court I.D. No. 93967 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 Counsel For: Ally Financial Inc. ALLY FINANCIAL INC., : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PA vs. CORA E. HOSTETLER, ADAM E. HUMMEL, Defendants : No. 14-3761 Civil : ACTION IN REPLEVIN NOTICE OF JUDGMENT TO: CORA E. HOSTELTLER & ADAM E. HUMMEL You are hereby notified that on 18 has been entered against you in the above captioned case: , 2014, the following judgment Judgment in favor of Plaintiff, Ally Financial Inc., and against Defendants, Cora E. Hostetler and Adam E. Hummel, jointly and severally, as follows: Possession of the 2013 Chevrolet Cruze bearing Vehicle Identification Number 1G1PA5SG2D7318372, and for judgment in the amount of $17,536.44, plus interest, late fees, reasonable attorney fees, costs of collection, costs of repossession, costs of storage and all other charges as provided in the contract or as provided by law, and increasing monthly. Judgment was entered pursuant to Pa. R.C.P. 1084 for failure of Cora E. Hostetler and Adam E. Hummel, jointly and severally, to file a sponse to Plaintiffs Complain within twenty (20) days of service thereof. Prothonotary I hereby certify that the proper person(s) to receive this notice under Pa. R.C.P. 236 are: Cora E. Hostetler 165 Lee Ann Ct. Enola, PA 17025 Adam E. Hummel 9115 Ridgefell Ave. Pittsburgh, PA 15237 NAUMAN, SMITH, SHISSLER & HALL, LLP oshua D. Bonn, Esquire Counsel for Ally Financial Inc. Dated: September 17, 2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLY FINANCIAL INC., : File No. 14-3761 Civil Plaintiff v. CORA E. HOSTETLER, ADAM E. HUMMEL, Defendants C : Costs (to be completed by Proth/Clerk)=;^ ,"- : Pltf. Paid : Deft. Paid : Due Proth/Clerk : Other Costs PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY OF SAID COURT: (Check appropriate block) (X) Issue writ of possession in the above -captioned case and direct Sheriff to deliver possession of the following property to plaintiff(s):2013 Chevrolet Cruze, VIN: 1G1PA5SG2D7318372 (_) to satisfy the costs against the defendant(s), direct Sheriff to levy upon the interest of the defendant(s) in the following property and to sell the same: (X) Personal Property as follows: 2013 Chevrolet Cruze, V1N: 1G1PA5SG2D7318372 ( ) Real Estate as per the attached description. Date: October 21, 2014 QM} s4 .. Sc �d a*1 151.25 C31 103.75<<u 1(p.Sou 411PH1.SO Pd°`t�`1 Signature: �J0- V, Print Nae: Joshua D. Bonn, Esquire Address: 200 N. Third Street, 1 8th floor Harrisburg, PA 17101 Attorney for: Ally Financial Inc. Telephone: 717-236-3010 ext. 26 Supreme Court ID No.: 93967 WRIT OF POSSESSION COMMONWEALTH OF PENNSY VANIA COUNTY OF CUMBERLAND TO THE SHERIFF OF SAID COUN Date: (1) To satisfy the judgmen deliver to the plaintiff(s) ossess ossession in the above captioned case, you are directed to on of the above described property. (2) To satisfy the cos against the s = endant(s), you are directed to levy upon any property of the defendant(s) and sel the defendant(s) nterest therein. cut 29991 Prothonotary/Clerk, Civil Division By: Deputy tuF Of lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLY FINANCIAL INC. VS. No. 14-3761 Civil Term CORA E. HOSTETLER, ADAM E. HUMMEL Costs Attorney's $ 246.50 Plaintiff's $ Prothonotary $ 2.25 DUE CO COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) ALLY FINANCIAL INC. being: (Premises as follows): FOR POSSESSION OF THE 2013 CHEVROLET CRUZE, VIN: 1G1PA5SG2D7318372, at Defendant Hostetler's residence: 165 Lee Ann Court, Enola, PA 17025 and her place of employment is Buffalo Wild Wings, 6385 Carlisle Pike, Mechanicsburg, PA 17050. (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. Date 10/23/14 (Seal) '/./J_Lb David D. Buell, Prothonotary, Common Pleas Court of Cumberland Coun , PA 2 of 2 No 14-3761 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLY FINANCIAL INC. VS. CORA E. HOSTETLER, ADAM E. HUMMEL WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 246.50 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: Joshua D. Bonn, Esq. Nauman, Smith, Shissler & Hall, LLP 200 N. Third Street, 18`h Floor Harrisburg, PA 17101 (717) 236-3010 ex. 26 By virtue of this writ, on the Attorney for Plaintiff (s) Where papers may be served day of , . I caused the within named , to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFT ICE OF THE S „RIFF 1 ..::.��r..�ri t"' 2015 AN 12 Pti 3: 14 CUMBERLAND COUNTY PENNSYLVANIA Ally Financial Inc. vs. Cora E Hostetler (et al.) Case Number 2014-3761 SHERIFF'S RETURN OF SERVICE 11/05/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Cora E Hostetler, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 6385 Carlisle Pike, Hampden Township, Mechanicsburg, PA 17055. Deputies went to defendant's place of employment, Buffalo Wild Wings at 6385 Carlisle Pike, Mechanicsburg, PA 17050 and learned that the defendant no longer works there. Deputies were advised that defendant possibly works at Nathan's Bar, 201 N Enola Road, Enola, PA 17025. 12/04/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Cora E Hostetler, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at Nathan's Bar, 201 N Enola Road, East Pennsboro Township, Enola, PA 17025. Deputies went to this address and learned that defendant no longer worked there. 01/09/2015 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED. No good address can be located for defendant. SHERIFF COST: $69.87 SO ANSWERS, January 09, 2015 RONR ANDERSON, SHERIFF "tf3/s,� (c) CountySuito Sheriff, Teleosoft, Inc. lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLY FINANCIAL INC. VS. No. 14-3761 Civil Term CORA E. HOSTETLER, ADAM E. HUMMEL Costs Attorney's $ 246.50 Plaintiff's $ Prothonotary $ 2.25 DUE CO COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) ALLY FINANCIAL INC. being: (Premises as follows): FOR POSSESSION OF THE 2013 CHEVROLET CRUZE, VIN: 1G1PA5SG2D7318372, at Defendant Hostetler's residence: 165 Lee Ann Court, Enola, PA 17025 and her place of employment is Buffalo Wild Wings, 6385 Carlisle Pike, Mechanicsburg,.PA 17050. (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. Date 10/23/14 (Seal) David D. Buell, Prothonotary, Common Pleas Court of Cumberland County e.cvz TRUE COPY FROM RECORD ; 2 of 2 No 14-3761 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLY FINANCIAL INC. VS. CORA E. HOSTETLER, ADAM E. HUMMEL WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 246.50 Plff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: Joshua D. Bonn, Esq. Nauman, Smith, Shissler & Hall, LLP 200 N. Third Street, 18`h Floor Harrisburg, PA 17101 (717) 236-3010 ex. 26 By virtue of this writ, on the named , to have possession of the premises described with the Attorney for Plaintiff (s) Where papers may be served day of , . I caused the within appurtenances, and Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy