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HomeMy WebLinkAbout14-4955 It COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial District, County Of Cumberland FROM MAGISTERIAL DISTRICT JUJD?E JUDGMENT COMMON PLEAS No. 1 5 Ct' NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT MAG.DIST.NO. NAME OF MDJ Velocity investments, LLC 09-3-04 T Kathryn Silcox ADDRESS OF APPELLANT CITY STATE ZIP CODE 1060 Andrew Drive West Chester PA 19380 DATE OF JUDGMENT (Plaintiff) (Defendant}' 7/31/14 Velocity Investments, LLC VS Ray E4ra er DOCKET No. SIGNATURE OF APPELLANT 4ARNEY OR AGENT CV-148-2014 This block will be signed ONLY when this notation is required under Pa. If appellant was Clai (see Pa. RC.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the Magisterial District Judge, will before a MagisterialDistri M I Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20)days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT(see Pa.R.C.PD.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon appellee(s),to file a complaint in this appeal Name of appelleets) (Common Pleas No. within twenty(20)days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To appellee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20)days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time,a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail ik1th4V0IA)kf3hj�,,ffi:Ming. Ziinoo oNv, �,jiairio Date: .20 8% .Z W J I � ON 1116Z Signature of Prothonotary or Deput,, YOU MUST INCLUDE A COPY OF THE NOTICE 00iirdl �T/TrANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 aaa� COMMONWEALTH OF PENNSYLVANIA 4A, Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND - Case r Mag. Dist. No: MDJ-09-3-04 Velocity Investments, LLC. MDJ Name: Honorable Kathryn H. Silcox V. Address: 5275 East Trindle Road Tina M Flagle, Ray E Kramer Suite 110 Mechanicsburg, PA 17050 Telephone: 717-697-2201 Velocity Investments, LLC. Docket No: MJ-09304-CV-0000148-2014 c/o Burton Neil &Associates, P.C. Case Filed: 5/2/2014 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Disposition Details Disposition Summary (cc-cross Complaint) _-- Docket No Plaintiff Defendant Disposition Disposition Date MJ-09304-CV-0000148-2014 Velocity Investments,LLC. Tina M Flagle Dismissed Without Prejudice 07/31/2014 MJ-09304-CV-0000148-2014 Velocity Investments, LLC. Ray E Kramer Judgment for Defendant 07/31/2014 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES,IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. r � Ll Date . The Honorable Silcox ;n certify that this is a true and correct copy of the record of the proceedings containing the judgment. Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed:07/31/2014 2:14:48PM aa� 4i Velocity Investments, LLC. Docket No.: MJ-09304-CV-0000148-2014 V. Tina M Flagle, Ray E Kramer i. Participant List Plaintiff(s) Velocity Investments, LLC. do Burton Neil&Associates, P.C. 1060 Andrew Drive, Suite 170 West Chester,PA 19380 Defendant(s) ;<4 Tina M Flagle) 264 Ridge Hill Rd Mechanicsburg, PA 17050 Ray E Kramer 264 Ridge Hill Rd Mechanicsburg, PA 17050 Complainant's Attorney(s) Derek Cory Blasker, Esq. Burton Neil&Associates 1060 Andrew Dr Ste 170 West Chester,PA' 19380-5600 MDJS 315 Page 2 of 2 Printed:07/31/2014 2:14:48PM ;LE.'ti FI(2.:" THE PROTHON011 20111 SEP -2 PM 2: 145 CUMBERLAND COUNTY PENNSYLVANIA PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served on a copy of the Notice of Appeal, Common Pleas No. 14-4955 Civil, upon the Magisterial District Judge designated therein (date of service) August 29, 2014, o by personal service by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) Ray E Kramer, on THIS (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME sender's receipt attached hereto. DAY OF , 20 o by personal service Eg by (certified) Veiled ail, August 29, 2014 Signature of official before whom affidavit was made Signa ure o affiant Derek C. Blasker, Esquire affiant makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities U.S. Postal ServiceTM CERTIFIED MAILTM RECEIPT (Domestic Mail Only; No insurance Coverage Provided) For delivery information visit our website at www.usps.come OFFItTAL USE Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & F Postmark Here 11 - 41/ PS Form 3800. August 2006 See Reverse for Instructions Lfl rU 1 rn o- ,ru rn rR 0 0 r9 r-1 0 U.S. Postal ServiceTM CERTIFIED MALTM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.comto Postage Certified Fee Postmark Retum Receipt Fee Here (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Feea or PO Box No, City, State, ZIP+4 PS Form 3800, August 2006 See Reverse for Instructions 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 VELOCITY INVESTMENTS, LLC. PO Box 788 Wall, NJ 07719 Plaintiff v. TINA M FLAGLE 6591 Carlisle Pike Mechanicsburg, PA 17050 and RAY E KRAMER 264 Ridge Hill Road Mechanicsburg, PA 17050 Defendants OF THE: Pf?0 I-10140 TA 2014 SEP 0 AN 10: 37 CLIMBERL AND PENCOUNT)/ NS YL W1/4 ti 1 A : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-4955 CIVIL : CIVIL ACTION - LAW 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 WI l'H 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 145758 / 304 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 Brit J. Suttell, Esquire, Id. No. 204140 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff VELOCITY INVESTMENTS, LLC. 1800 Route 34 N, Building 4, Ste 404A Wall, NJ 07719 Plaintiff V. TINA M FLAGLE 6591 Carlisle Pike Mechanicsburg, PA 17050 and RAY E KRAMER 264 Ridge Hill Road Mechanicsburg, PA 17050 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-4955 CIVIL Defendants : CIVIL ACHON - LAW Complaint 1. Plaintiff is Velocity Investments, LLC, with place of business located at 1800 Route 34 North, Building 4, Suite 404A, Wall, New Jersey. 2. Defendant is Tina M Flagle, who resides at 6591 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania. 3. Defendant is Ray E Kramer, who resides at 264 Ridge Hill Pike, Mechanicsburg, Cumberland County, Pennsylvania. 4. At all times material and relevant to the transactions set forth herein, Pennsylvania Water Specialists, Inc. together with American Finco Financial Services, LLC were engaged in the business of financing the installment sales of water treatment systems and are authorized to conduct said business. 5. On or about November 28, 2008, Defendants applied in writing for a personal loan from Pennsylvania Water Specialists, Inc. together with American Finco Financial Services, LLC. 6. A true and correct copy of the defendants' loan application is attached hereto, marked Exhibit "A" and incorporated herein by reference as if set forth herein in full. 7. On or about November 28, 2008, Pennsylvania Water Specialists, Inc. together with American Finco Financial Services, LLC approved defendants' loan. 8. Enclosed herein and marked Exhibit "B" is a true and correct copy of the completion certificate executed by the Defendants upon installation of the water treatment system on or about December 2, 2008. 9. Defendants breached their obligation under the contract by failing to make the required monthly payment when due. Defendants last made a payment on or after May 31, 2011 and the entire balance was declared due and owing. 10. On or about June 25, 2010, Plaintiff acquired this account from American Finco Financial Services, LLC. A true and correct copy of the bill of sale is attached hereto and marked Exhibit C. 11. Although demand has been made upon the defendants to pay plaintiff the sums justly due and owing, the defendant has failed and refused to pay all or any part thereof WHEREFORE, plaintiff demands judgment again e defendants in the sum of $4,099.65 plus the costs of this action. Burto & Associates, P.C. By: De . Blasker, Esquire Attorney for Plaintiff 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. 172643 / 205 Dec -05-08 08,: 21A f wtmi,o Whose. easi611t1. R you aro Etching rut Yl:dll.illtd I000JOt Or. lain! rood r,ic1 locations Mbar pan Mb ste.st, o0tl Ant socusr gab hits ViAttorski, sotahon your fro i t0.mMlon .uta racy Dooma tiv,.i t i11tm aist n in Soo A r. R .. apphr{rilte. Merchant if- 1� Requested Amount J6 yar7 .c P . 02 It/2 American Finco Credit Program A Ern 3 515@ rw) f, j he s !a•IO,11/ 0000331 IOU UC Mir./ Ir•. JOINT CREDIT, .111mutter utter wren00) tor 1.000)0 o 010, , A 0. IXDMOUAI CREDIT. Oa co taco=A it C. Section e - Inter on About Yet/tali I.. h1eXk entail a L rsn ess r toy ibbC eawNwn.! Nina Veli ow t-10*KA,e' (i I) (9IA%"c4 (f iris *Idlers �r 1./t Uty, Tiro wars at preuno .. 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NOTICE RN NEW YVNI RESIDFNT0I Wit Yon n:Jit:als mat combat Ms Now Yoe, Stain Rtnlia D7to 1020* N o1Mm 1 a CorM1CW keine M used cut ince I.c foul Or" ter W 1. now Yon Amery hq.W ultd 1.11OIE5166166. PID, I t FUR Cleo RESIDENTS' TTr Nie that 1¢1:11 ascot=5n 1qu110 that of oadbs mkt Clan .duty '400aq. el 01ma h1 a creel •wormy ts, iw eat vats, r.Ty .a .o00ei I club 1 agar= QCt,a hc1xicA Y 1 e1 hnl. lo31 t1oo. 0.pwotent Tht pro tans tet CWTirniss p0) I40vr...0s e0.t1N.00 VAI x10108 111111111 S I 11111 11111 SYu . Mire Annual percentage rate (APR) for purchases 19.99% Other APRs Grace period for repayment of the balance for purchases The Default APR is 26.99%t 20 days Method of computing the balance for purchases Average Daily Balance (including new purchases) Minimum finance charge $1 Late payment tee ACCOUNT li tTlK Debug Nate w+tl apply if you tail to matte ten tonsaciltive Total Minimum Paymonts Doc af10 are 30 a yc past dm I (--1 I $39 LOSURES ARE NOT ATTACHED 7 71 50 0 3 - o0 z ii 0 1 x0 zr a C7 8* a tri 0 C, cc cc 0 c 0 7 cc 0 S W V W 1211 ap z 4 EXHIBIT A Oec—Q4-08 09:53A ' • AmericanFlNCO ACCOUNT I# I - Merchant # B)ryer's Name: 771fhl.' 616.6; Seller's Nance and Address (Denier, please print or stamp information below): • ., dt i' fl .9( akIS 2, • _ tui, — /:6 1 (4- P. 04 ErNew 0 Picked -Up C] Add-Oti 0 Delivered ❑ Credit 8 -installed Date of St+1c/Trar)saction: 11 / . / 6.13 Late of Delivery/Insudlu ' n:/ Salestntsn Name/ID:._ ! it �' Qan: Auth. Code Description �I--J Sale Price • a .sZ) 7C �n Grarlil Platt 11 — Code :It/••{uti.;d Irtr .tit .ik'.: otxxl7-XX lire n'llI II I nnnli•ntal) • • CTC: I�HI !xiXl FOR CREDIT PROMOTIONAL SALE ONLY This sentient pertains only to the term and length of any credit ptnntnsinm. It does NO t pertain to atty'trial' petiutis yr other types of prat orions ()tiered by die deal,•,: Fess details of all Ptutnatioual Credit Plans. please refer to your Cardholder Agreement and Disclosure Statement, the Genus of which ate intr+rprnntrd herein. ifapplicnblr- Proamotion Length: - --•-•-•- - -- Your pivuruliun will expire in - __ months (from the date at possession). Promotion Type (SELECT ONLY ONE): �j f Reduced Monthly Puymcat Credit flan/Reduced kite Credit Plait: lhtring the specified period, the Minimum Monthly t'aytnrut it. ein•.•.`er.nn with this purchase will be reduced to % us $35, wit ichevet is greater, and the periodic rate for dais purchase will ht % (APR), as lurch as the Taal Minimum Payment Due is pail wttcu due each billing cyt 1r,. NOTE:Virus M• • m Monthly Payment and Pet iodic Rate (RPR) will increase as the capirminn atltis Special Credit Promotion. ❑Warred Finance Charges Credit Pions During the apeeinert period no Finance (*.harps will be imposed on your purchase as lung as (hr Total Minimum Payment Due is paid whcu due each billing cycle. flWaived Furore. Charge/Delayed Monthly Payment Credit Plan: No Loans e Charges will he imposed on the pnrr•hau: For the specified period and un Mininnl.n Moodily Payntrnrt on the purchase will be due for die specified pct hal. Yon still are required to pay the Total Mulitnuu Payment itee r:ar), haling eyrie during the spec• iftett period. riDeferred lmance charger/D.•lay.ot Monthly Payment Credit Plan: U you pay flys fall cosh sales para r ..i ,1w pru•rh:tse hn:lierC the promotional due dale ii i,lieaterl on your billing statement, n.. Finanre Charges will be imposed on the put. Tear. If mannllt in run is out made hassle that date-, Finance C3targcs will be iutps•i•a1 from the pus chase Anne. No Minimum Payments will be due on the purchase prior to the its motional attic ,late :•sind,c:.letl uu Ilii, Billingstateuuvt, Von are. still reyulted its pay the Ttxal MilIimntm Pay,rn•ul Dur (-Arlo }idling t yele clouting the sp.•citirtl pi•riud. nttc-duced Bair Credit Plan: Dutinti at, s1u•r•;re•d Is•rii,d. the reduced pro hall. rata 1 1 fun this (,it i h:nr will la• . % (APR). as long as the Total Minimum Pat Otte is lad whto earl, Tolling reek. - X iiia. gig" i 1 �`a�i� 25 txdle-s ...storey k - farm ?Oat I11.ut.-4L.•elll/ll. Rt(tiVol/,n) SUB TOTAL 3 Z. 7' I �- SAI. ES TAX `I �, s CA411 PRICE , 5 tl f.) t"-- CASH DOWN PAYMENT C) BALANCE (AMOUNT FINANCED) ?J J` •7�GI BUYER'S RIGHT TO CANCEL YOU, i i IIF BUYER, MAY CANCEL. THIS 'TRANSACTION , i• ANY TiME PRIOR TO MIDNIGHT OF THE THIRD BUSTNFSS DAY (FIFTH BUSINESS DAY iN ALASKA.; FIFTEENTH BUSINESS DAY IN NORTH DAKOTA IF YOU ARE 65 YEARS OF AGE OR OLDER) AFTER 'THE DATE OF TELLS •TANSAC;TION. SEE THE ATTACHED NOTICE, 01" CANCELLATION FORM FOR AN EXPLA- NATION OF THIS RIGHT IF THE ABOVE MEN- TIONED FORM IS NOT GIVEN TO YOU DO NOT SIGN YOUR NAME To THIS TRANSACTION. NEW JERSEY RESIDENT'S: FAII.URF. TO EXERCISE THE OPTION TO CANCEL THIS TRANSACTION WILL NOT INTF.RFERE WITH ANY OTHER REMEDIES AGAINST THF RETAIL SELLER YOU MAY YOSSI?SS. A DUPLICATE OF THE NOTICE OF CAN C:ELL.AI'IO N FORM IS PROVIDED BY THE RETAIL SELLER FOR YOUR RECORDS. nnyer acknowlealgrs creeps or a roinpieted roles til thio S:dca Slip and the attacher) Notice til C u,ettlatiutt lotus :nut luuwbca to pay the unpaid ixtltnee pita any Finance Charges and less due f(. the purchase ..rd.. greats and/tit sees - ices described alxwr in arcnrdancr with the terns til die C:Lutdtttldee Agreement and Dock.ause St-tcutan. AKIZONA. CONNECTA::UT. NURTU DAKOTA AND RHODE IS1AN1) RVI. DF.NTR% NQNNF.Cf)TIAt1I.F. CONSUMER NOTE: TillS INSTRUMENT 1S EASED UPON A 11(151 B(PERSONAL soUCTTATION SALE. WHICH SAVE IS SUBJECT TO'1iil: PROVISIONS OF TTTI•F 44, CHAITITE 15 or TDP. ARI. ZONA REVISED STATUTES IN ARi7.ONA, TILE HOME SUUCTI•ATION SALT. ACT IN CONNECTICUT AND THE NORTH' DAKOTA CTNT RV CODE IN NORTH DA/USTA. THUS INSTRUMENT IK NOT NF.C:CTRAW..E. Da not sign tbia agreement If any el the spies catenate$ ray the .greed w.... to the osteal of mat available armatteo a.. telt W.A. Yrs.. he nodded to a refer• of this •iPancomi .0 Ote u my I..) on ah. Esso ....d Intone* dun =WI*. sa.eeteeot ..1•117 cs.s•_ arcA i.... .1 inlay ..,r,... 1.11 r.l.aae „ r ti,. warn Mil n.tutte ori (Manua ahvxe.. The vans - . nlr• gine prrwire..otwfa.�..v ..w.w1t al Maid. of the raw,: .apo. tem Roods -, •.-•.. d under nth Oec-04-08 09:53A P.05 AmericanFiNCO NOTICE OF CANCELLATION Minnesota tri Jenrt (type agoutis or services ix..clo:.a rf-Zcc- a Date ot'lianuction: You may C.ANCEi, this transaction, without any Penalty ur Oblig:)tioa, • within THREE BUSINESS DAYS (five (5) hte.incss days in Alaska; Ylt'• , TEEN BUSINESS DAYS in North Dakota if you are 65 years of age ur older) from the above date. If you cancel, any property traded in, any payments wade by you tinder ' the contract or sale, and any negotiable instrument executed by you will be returned within TEN itUSiNESS DAYS (TEN DAYS if you live in California. the District of Columbia, Georgic, Mississippi, Missouri, Montana or Vermont), following receipt by the seller of your eana:ella- lion notice, and any security interest wising out of the transaction will be cancelled. 1f you cancel, you must make available to the seller at your resideuce, in , substantially ars good condition us when received. any goods delivered to you under this contract or sale., or you may, if you wish, comply with the instructions of the seller regarding the return shipment of the goods at the seller's expense and risk. (if you live in Arkuncay you are obligated ao return the goods only if the seller has returned any payments and goods or other property received from you.) If you do make the goods available to the seller and the seller does not pick them up within 20 days of the date of your Notice of Cancellation, you may retain or dispose of the goods without any further obligation. If you Gail to make the grinds available to the seller, or if you mt ree to return the goods to the seller and fail to do so. then you remain liahlc fur performance of all obligations wader the Contract. To rantel this transaction, mail or deliver a signed and dated co y of Ibis Cancellation Notjce or any oil[ wrilt t tau or.:sen, s tel .snit to: NOT LATER THAN MIDNIGHT OF 1- t`; rC (Date) I HEREBY CANCEL THIS TRANSACTION. X (!late) (tkryer's Signature) ACKNOWLEDGEMENT OF RECEIPT OF NOTICE OF CANCELLATION i hereby acknowledge receipt of the completed Notice of - Cancellation fort .t forth above. and dun Use Seller has orally informed meof4-Cg X t y r };est to c (late) (Nuys 's Signature) atuoter4,a5 res orwalimi FINCO COPY NOTICE OF CANCELLATION Minnesota resident, (iypc of goods in services pnrchasen) Darr. nrTrantat.tion: You may C•ANCE1. this transaction, without any Penalty or Obligation, withal '1'HKEE BUSINESS DAYS (Svc (5) business days in Alaska; FIF- TEEN BUSINESS DAYS in North Dakota if you are 65 years of age or older) front the above date. If you cancel, any property traded in, any payments made by you under the contract or sale., anti auy negotiable instrument executed by you will be returned within TEN BUSINESS DAYS (TEN DAYS if you live in California, the District of Colwnbia, Georgia, Mississippi, Missouri, Montana or Vermont), following receipt by the seller of your cancella- tion notice, and any security inter at arising out of the transaction will he cancelled. If you canerl, you must make available to the seller at your rtaidence. in substantially a -R good condition as when received. any goods delivered to you ander this contract or sale, or you may, iryou wish, comply with the instructions of the seller regarding the return shipment of the good, at the. seller's expense and risk. (If you live in Arivansas, you are obligated to return the goods only if the seller has returned any payments and Kuda or other property received from you.) If you do make the goods available to the seller and the sclltcr does nut pick them up within 20 days of the dale of your Nnrice of Cancellation. you may retain nr disperse of the goods without any further obligation. If you fail to make the goorli available, to the seller, or if you agree to return the goods to the seller and fail to do in, then you reru:aur liable for performance of ull obligations tinder the contract. To cancel this transaction, mail or deliver (:ancelluunn NO or atother [ten n !N:wle,','Ilc e G•ar' nf/ .S)11' Fey f ' tee's Met: ul ll ) / k e /1604 (City. ST, lip of Sellers Elam. of Business) ted anti dated ropy F this or scud -Pee C.- r. NOT LATER THAN MIDNIGHT Or (nate) I I IEREBY CANCEL TIIIS TRANSACTION. X (Tarte) ACCOUNT # (Buyer's S'gnatere) �,f n,,,..5101 A11.17/24r01 M V6i01/051 FINCO COPY Dec -Q4-08 09:53A P.03 AmericanFINCQ Dear Homeowner.' Ely signing the Completion Certificate pit ARE NOT it Kt FAS responsibility to: C•• ,c•�er_.?ic't from their ctuuractual ISen. r i Naune) I. Keturn and mike any corrections, repairs. and testing of rynipmt•nt installed before rltr weather allows. 2. Report and correct any manufacturer's defects. 3. Rcspond CO any future service calls by you. COMPLETION CERTWFtCKUE CAUTION TO BUYER DO NOT SIGN THIS CERTIFICATE UNTIL ALL SERVICES HAVE BEEN SATISFACTORILY PERFORMED AND MATERIAL SUPPI.IF.D OR GOODS RF.CE1VED HAVE BILEN FOUND SAUSFAC:TORY. '1b: American Fu1Co )financial Serviette, LLC. Buyer(s) ("You". "Your") herby certify that all the work, rrlui(Orient anti matrriais, covered by t:untraCt bctwrett (San , N7nt0) equipment and materials leave been inspected by yon. Von fitrtlter certify tL;o a!1 sono advanrrnl under your Revolving Credit and you datcd 11 12' s. las; been satisfactorily completed and said work. Acrount danxl• t l `]-`.6 were toed I'ctt' the purpose of inrptowing rr.al property located at: AI; 1772—Ne • , 4't \ 1 -I-2t_ NC)TICE TO IJYVR/OWNER (NF.W,JER.SEY RI:AMEN-IS 11NI.V) Do not ' this Completion Ccrttiicate nr any agroottent stati.lg yon arc saint icrf with the entire pro .t Fx:fort• this project i .•r.mpietr•. The . ome repair contractor is prohibited by law front rwlnewting or accepting a certificate of completion Piigtred by Ow buyer/owner prior ental completion of the wont un be pc-rfurtnrd under u retail installment contract and security ugrceinettt/horrre repair contract. U _ r SytntllVEC hereby certify that (1) I have delivered rho afutrsaid equipment. and material and installation thereof was Completed by C in a workmanlike. nnirnter. (2) the above Certificate was signed by the customer after completion of the installation, and (3) ail debts for labor, license fees, prrutit.. inspection fees:mil other hills pet tailing to the customer's contract have been paid in full and there will be no mechanic's, materfatrntn's nr cttlter lie•.n(s) on custmorr's resirlcuce as a consequence of said insrallatitnt. SYL).F.R: C -Y ��:N\\i( r;tC CJi!'i.� <_..t c\ --k SLGNATIIRE: �'ci.4r%� r a? !L U ACCOUNT # r r ) r.,.«. tutu) nu.u7/taaq PD(US/nr/u.•+) II I I I EXHIBIT B EXHIBIT C ASSIGNMENT AND BILL OF SALE American Finco Financial Services, LLC, (hereinafter collectively called "Seller"), for value received and pursuant to the terms and conditions of the Purchase and Sale Agreement dated as of June 25, 2010 ("Agreement") between Seller and Velocity Investments, LLC (hereinafter called "Purchaser"), do hereby sell, assign, and transfer to Purchaser, its successors and assigns, all of Seller's rights, title, and interest in and to those certain Accounts and Accounts Receivable (which terms are defined in the Agreement) listed on Exhibit A attached hereto. Purchaser and Seller agree that the Purchase Price (which term is defined in the Agreement) shall be as stated in Paragraph 3 of the Agreement and as set forth in the Closing Statement attached to the Agreement. IN WITNESS WHEREOF, Seller has signed and delivered this instrument on the 25rd day of June 2010. American Finc By: Name: o ert Kan Its: President Ser PURCHASER ACKNOWLEDGES & AGREES TO THE ABOVE: By: Name: James J. Its: CFO and C gal Officer EXHIBIT C Verification Derek C. Blasker, Esquire, attorney for plaintiff, VELOCITY INVESTMENTS, LLC. , makes this statement on its behalf as to the truthfulness of the facts set forth in the foregoing Complaint subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Counsel, rather than an officer or other representative of plaintiff is verifying the foregoing Complaint because plaintiffs officers and/or representatives are outside the jurisdiction of the court and the verification of none of them could be obtained within the time required to file this pleading. Plaintiffs counsel is yen p1intiffs Complaint based upon information and belief from information in his file. Date: vok Dere Blasker, Esquire Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY • r'���u-u�.'.�� pRo-H0���`[,, 7114S:P30 PM q: 42 CUMBFD(ANACOUQTy PENNSYLVANIA nt „ cT. OF "WE 1;;HERiFF VoocityInvestments, LLC vs. Tina M Flagle (et al.) Case Number 2014-4955 SHERIFF'S RETURN OF SERVICE 09/17/2014 09:30 AM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diverion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Ray Earl Kramer at 264 Ridge Hill Road, Silver Spring TownshipMechanicsb PA 17050. 09/19/2014 04:04 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Tina M Flagle at 6591 Carlisle Pike, Silver Spring Township, N1echanioehurg, PA 17050. SHERIFF COST: $67.09 JON KINSLER, DEPUTY SO ANSWERS, September 22, 2014 RONIq R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY HI nOTHONOU,k 7tROCT-IPH 2:3; CUMBERLAND COUNTi' PENNSYLVANIA Volocity Investments, LLC vs. Tina M Flagle (et al.) Case Number 2014-4955 SHERIFF'S RETURN OF SERVICE 09/17/2014 09:30 AM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint and Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Ray Earl Kramer at 264 Ridge Hill Road, Silver Spring Township, Me csburg, PA 17050. UTSHALL, DEPUTY 09/19/2014 04:04 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requestedComplaint and Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Tina M Flagle at 6591 Carlisle Pike, Silver Spring Township, Mechanicsburg, PA 17050. JAS KRIS< , DEPUTY SHERIFF COST: $67.09 SO ANSWERS, September 22, 2014 (c) CountySuito Sheriff, Teleosoft,nC. RONN R ANDERSON, SHERIFF VELOCITY INVESTMENTS, LLC. PO Box 788, Wall, NJ 07719 Plaintiff v. Tina M Flagle 6591 Carlisle Pike Mechanicsburg PA 17050 and Ray E Kramer 264 Ridge Hill Road Mechanicsburg, PA 17050 Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-4955 Civil : CIVIL ACTION - LAW Praecipe for Default Judgment 145758 / 221 Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL Velocity v. Tina M Flagle $4,099.65 $4,009.65 Velocity v. Ray E Kramer $4,099.65 $4,099.65 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last -known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembe the defendant is not in the military service of the United States b the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOV NOTICE G►VEN`IJND .R.CIV.P. ivil Relief Act of 2003 (SCRA), d on information received from it & Associates, P.C. Derek C. Blasker, Esquire Attorney for Plaintiff I.D. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 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. Q &k 16.SD-1)Q a-) i�1��rp 11(1n:la f) i n 11/4.1n 145758 / 265 VELOCITY INVESTMENTS, LLC. Plaintiff v. TINA M FLAGLE Defendant TO: Tina M Flagle 6591 Carlisle Pike Mechanicsburg PA 17050 DATE OF NOTICE: October 15, 2014 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-4955 Civil : CIVIL ACTION - LAW 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 (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 paper to your lawyer at once. If you do not have a lawyer, go to or telephone the office 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Asso 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 80 -990-9108 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. Burton By: Derek C. Bla " e Esquire Attorney for Plaintiff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 ssociates, P.C. VELOCITY INVESTMENTS, LLC. v. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA TINA M FLAGLE and RAY E KRAMER Defendants TO: Ray E Kramer 264 Ridge Hill Rd Mechanicsburg PA 17050 DATE OF NOTICE: October 09, 2014 : NO. 14-4955 Civil : CIVIL ACTION - LAW IMPORTANT NOTICE 145758 /265 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 paper to your lawyer at once. If you do not have a lawyer, go to or telephone the office 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. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Str Carlisle, PA 1701 Telephone No. 717-249-3166 or -990-9108 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. Burto & Associates, P.C. By: Derek C. r, Esquire Attorney for Pla'ntiff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 • 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 VELOCITY INVESTMENTS, LLC. Plaintiff v. Tina M Flagle and Ray E Kramer : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-4955 Civil Defendant : CIVIL ACTION - LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on 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 19380 Phone: 610-696-2120 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.