HomeMy WebLinkAbout05-2254IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLV IA
SHERMAN ACQUISITION II, LP
ASSIGNEE OF
SEARS, ROEBUCK AND CO.
15 SOUTH MAIN STREET
GREENVILLE S.C. 29601
Plaintiff
VS.
CARLA E WITTER
27 SHORT LN
SHIPPENSBURG PA 17257-9453
Defendant (s)
NO.
NOTICE
CIVIL ACTION - LAW
You the following have been sued
es, in you Court. must take action you wish to
thin defend (20) agaidaysnst after clthiaisms C set ompl ortth in
and
Notice are served, by entering a written appearance personally or by an att rney
and filing in writing with the Court your defenses or objections to the cla ms set
forth against you. You are warned that if
without you and a judgment may be entered agyou ainst1youobyothe,Courtcwithout urther
notice for any money claimed or any other claim or relief requested by the Ilaintiff.
You may lose money or property 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 OU WHERE
YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRIN A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YO WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
NOTICIA
Le han demandado a used en la corte. Si used quarere defensas de esas deman as
expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo a partir
de la fecha de lademanda y la notifiation. Used debe presentar una aparienc a
escrita o en persona o por abogado y archivar en la corte en forma escrita sus
defensas o sus objeciones a last demandas en corta de su
si used no se defienda, la corte tomara medidas
y Psedido persona. ona. una Sea Orden c den c o que
used sin previo aviso o notification ntra
en la petition de demanda. Used por cualquier queja o alivio que es p dido
derechos importantes para used. Puede Perder dinero o sus propledades o otr s
LLEVE ESTA DEMANDA A UN ABODOAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE
EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEF NO A
LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE UEDE
CONSEGUIR ASSITANCIA LEGAL.
Lawyer Referral Service
Cumberland County Bar Assn.
32 S. Bedford St.
Carlisle
800-990-9108
PA 17013
CVRNOT/PARET W&A FILE NO. 122231464
1 01
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SHERMAN ACQUISITION II, LP
ASSIGNEE OF NO.
SEARS, ROEBUCK AND CO.
15 SOUTH MAIN STREET
GREENVILLE S.C. 29601
Plaintiff
VS.
CIVIL ACTION - LAW
CARLA E WITTER
27 SHORT LN
SHIPPENSBURG PA 17257-9453
Defendant (s)
COMPLAINT
Now comes the Plaintiff, SHERMAN ACQUISITION II, LP
attorneys, and the law firm of Wolpoff & Abramson, L.L.P. by and throe
and in support avers as follows: and files this C
1. Plaintiff, SHERMAN ACQUISITION II, LP
ASSIGNEE OF
SEARS, ROEBUCK AND CO.
15 SOUTH MAIN STREET
GREENVILLE S.C. 29601
is a business entity doing business within the Commonwealth of Pennsylvania
other states of the United States.
2. Defendant, CARLA E WITTER
a last known address of is an adult individua:
27 SHORT LN
SHIPPENSBURG PA 17257-9453
COUNTY OF CUMBERLAND
3. It is averred that Defendant(s) was/were isued an open end credit
card account. The Terms and Conditions governing this account is attached he
incorporated herein and marked as Exhibit "A".
4. At all relevant times material hereto, Defendant(s) has/have used s
charge card for the purchase of products, goods and/or for obtaining services
igh i t s
)mplaint
and the
l with
reto,
iid
CCPWRI/PARET W&A FILE NO. 122231464
5. Plaintiff provided Defendant(s) with copies of the Statements o Account
showing all debits and credits for transactions on the aforementioned credit card
account to which there was no bona fide objection by Defendant(s). A true! and
correct copy of the Statement of Account is attached hereto, incorporated herein,
and marked as Exhibit "B".
6. As of the date of this Complaint, the remaining balance due, owi
unpaid on Defendant's credit card account as a result of the charges made g and
Defendant(s) and/or any authorized users is the sum of $ 16492.01. Y said
7. Pursuant to the Credit Agreement and/or applicable Pennsylvania aw, any
unpaid or delinquent balances on said account shall continue to bear interest at the
rate of 18.00%. See Exhibit "A" as previously identified herein.
8. As of the date of the filing of this Complaint, the amount of interest
which has accrued is the sum of $ 7937.85.
9. As of the filing of this Complaint, Plaintiff has incurred reasonable
attorney's fees from the law office of Wolpoff & Abramson, L.L.P. in the collection
of the amounts due from Defendant(s) incident to the within action based Upon 20% of
the principal amount due and owing, and Plaintiff shall continue to incur s ch
attorney's fees through the conclusion of the proceedings.
10. The amount of attorney's fee which has accrued is the sum of $ 3298.40.
11. Despite reasonable and repeated demands for payment, Defendant(s) has/have
refused and continue to refuse to pay all sums due and owing on the aforementioned
account balance, all to the damage and detriment of the Plaintiff.
12. The amount in controversy exceeds the jurisdictional amount req iring
compulsory arbitration.
WHEREFORE, Plaintiff respectfully requests this Honorable Court enter J
in favor of the Plaintiff and against Defendant(s)
Plus attorneys fees in the amount of in the amount of $ 16492.
$ 2
$ 7937.85, plus costs of this action andany4otherlreliefeassthis Courtmdee
and reasonable.
Respectfully submitted,
y
Amy Doyle # 2
Daniel F. Wo son #20617
Bruce H. Che is 4118837
Philip C. Warholic #86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer, III #89451
WOLPOFF & ABRAMSON, L.L.P.
Attorneys in the Pra
267 East Mark
t ctice of Debt Col]
e
St.,
(717) 846-1252 York, PA 17403
Counsel for Plaintif f
udgment
)1,
t of
as just
ection
CPWRI2/PARET W&A FILE NO. 122231464
ATTORNEY VERIFICATION
I hereby state that I am the attorney for the Plaintiff, who is located
outside of this jurisdiction and in order to file the within document in an expedient and timely manner, am authorized to take this verification on behalf
in
said Plaintiff in this action and verify that the statements made in the foregoing
Complaint are true and correct to the best of my knowledge, information, a d
belief, based upon information provided by the Plaintiff.
The undersigned understands that false statements herein are made sub'ect to
the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsificatio
to authorities.
Date:
Amy FY Doyle #87062
Daniel F. Wo F #20617
Bruce H. Che
kis #18837
Philip C. Warholic #86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer, III #89451
WOLPOFF & ABRAMSON, L.L.P.
Attorneys in the Pra ctice of Debt Cc
267 East Market St.,
(717 York, PA 17403
) 846- 1252
Counsel for Plaintif f
dlection
PAVERF/PARET W&A FILE NO. 122231464
EXHIBIT "q"
ATIONAL BANK
111W?11ADSCARD
WA-?e
ACCOUNT AND SECURITY AGREEMENT
RETAIL INSTALLMENT CONTRACT
t AND SECURITY AGREEMENT (CT)
RETAIL INSTALLMENT CREDIT AGREEMENT (NY)
1. DEFINITIONS. in the agreement,'SNB' means Sears National Bank
or any subsequent holder of my account or any balances arising
under my account and 7" fie; my,' refers to all persons named on
the credit application or acceptance certificate, as an accountholder.
WSNB ' ry (SFHC?. weed subsidiary of Sears Financial W irg
Roebuck and Co. wick Y owned subsidiary of Sears,
2. ACCEPTANCE AND LIABILITY. I am nesponsr for an amounts
owed on my account. I agree to repay all amt nts owed on my of th effective whr n any ccountholder oriaNoriz?ednu?ser? agreement is
account, activates the card, or takes any other adan>?rl ca1eS
ac Eance of the account or card.
3. OPTION TO PAY N FULL EACH MONTH, GRACE PERIOD. l have
the right each month to the total New balance on my account I
- I do So within 30 (28 or February statements) of my biUug
date, rn FinarlCe Charge wil be added for that math. The due date
win be shown on my illy statement- The total balance onmy
4. O11PTfON date TTO?PAY NIIINSTALNLMMENNTIS.N I cumts)?payy e:ttDWbacl• ance in full each month, I spree to Pay at least the minimum
5. A OU der
AR ES SUB?IEC TO APP OVAL of This al payinall e
agndapp an charges on the account are subject to SNB'sp approval. The
of aroval od mebe nsidered . SNB will notbe liable tame n SNBr nable?o
authorize a due to a on on account, even if I have sufficient avail.
6. able AND H on in SN USE .? system. Pwshases. I may authorize or Permit is to make purchases
and use the account. I agree that this Agreement controls all charges
? Y those persons, that I am responsible for all purchases and
oY dcse persons and I agree to Pay all such put-
t
chases and charges I authorize SN o ad at the request of those
ppeersats and I wilf not hold SNB responsible or liable for such action.
(b) A0r1zed Users. Arty Person whom I have designated as an
authorized user ('autho as provided below may use the
account and take any action with sped to the
take account that I cow
. I make this designation by notifying SNB of such aulho.
rized uselr(ys) by haling the number written below or providing
written notice at the address written below. In making
I request that a credit card be issued to the authorized user and I
understand and agree that (a) this a reTW controls all charges
made on the account by lyre riersoh(s) led by me as an au81o-
rued user and I understand t l am responsible for all purchases and
charges made by authorized users and I agree to pay an such
charges, (b) SNB may disclose information about the account to
persons I dasgneastonn a
making such ddeess
p? mhtarry authothe rized user the
k) by
iser to tre d
agent for rposes of dealing with the account in the same mamry a
1 Pu
, and S NB n
as
can wiltout
requests d airy any habilty, accept the directions or
account and aW n d eesgnated as an authorized user of the
10 Process requests to raise tale crsuch edit limit directions or requests, hrhdt unL
1 may add, terminate or change authorized users ?blf the acctat
callin 1-800347-8480 or by providing written notice to SNB P.
Bon 555, Columbus. OH 43216. t I terminate this authority, I will
afiempt to retrieve the credit card from the pe desp?
milted or authorized to use the account and ha a card tom' Per.
(c) Unauthorized Use. If I believe or claim that any charges
account are unauthorized, I aQr?ee to ratify SINE immediaely at t e
address indicated on my momilly statement, upon discovery and to
cooperate with SNB in making a reasonable investbigpaairon of my
claim. Unauthorized use does not include use by an authorized user
or a person to whom I have given the credit card or authority, per:
mission or designation to use the account, including wifiotrt
lion anyone I have designated as an authorized user pursuant ro the
sP revioues? graph, and I will remain liable or any and all use by
7. CONSUMER ACCOUNT. I agree to use this account only for
sonal, family or household pun hcsefoand all transactions wiN be
deemed to be for rsonal, farm w lo Puffs
a. CREDIT LIMIT. SNB will disclose my credit lima to me when the
account is kOpenede and on each monthly statement, and may
m to tirne I agree not to
exceed the credit limn established by SNB.II undersyarid and
that my credit limit can be increased or decreased at the request agree
of a
1
12. MINIMUM PAYMENTS. The scheduled monthlment is based
on the current New Balance on the a y Payment The scheduled is based
payment will increase and decrease alt with an the balance. The min-
'mum payment each month will equal the scheduled nonthly pay-
understand that the t required? minimum on my statement. I
monthly statement lit may vary from the sclhedulnedsrn hly, payment
When the current New Balance is: The Scheduled Monthly
$ .01105 10.00 Pa_yment? :
10.0110 250.00 The$1BOa00
250.01 to 300.00
300.010 350.00 11.00
350.01 to 410.00 12.00
410.01 to 470.00 13.00
470.01 to 550.00 14.00
550.010 605.00 15.00
605.01 to 660.00 16.00
660.01 to 720.00 17.00
720.010 760.00 18.00
760.01 to 640.00 19.00
Over 840.00- 1142nd of the Current New
Balance rounded to the next
higher whole dollar amount
I can aVs %r more than the required minimum paymant•
13. PAYMENTS. payments made by mail should be made
liable instruments drawn on federally or state chartered U.S. Wri.
cal institutions. Payments received at the pa0y0melit processing loca-
bbusi. dray will posted as Of the date of receipt.
I erus
reaeivetl a l l hat location after 1:00 PQ local time willbe posted to
V. account the need business day. The business days of SNB are
Monday through Friday , exdudmgg federal holidays. Payments
received at arty other ovation may be delayed in Poshrg up to fine
days conditional check, money order or any other instrument
tende as full satisfaction of a disputed debt or containing a restric-
live endorsement must be sent to SNB's address for billing error
notices, shown on the front of the monthly statement.
14. DEFERRED PAYMENT, DELAYED BILLING OPTIONS. Deterred
Payment Option. Under the Deferred Payment option when onered
2
I may purchase and charge selected merchandise or services to my
aceouit and 1 will not have to make monthly payments on these ser-
vices or merchandise or a ?Ki ied period of time: however. I will
have to pa regular Finance Charges on those purchases during the
period of the deferral.
Delayed Billing Option. Under the Delayed Billing Option when
offered, Purchases of merchandise or services will not be billed to my
account until the end of the delayed billing period. No finance
charges will accrue and no minimum payment will be due on the
amount of my delayed billing purchase until the end of the promo-
tional period. If I elect this option when offered. SNB will not be
required to give me advance notice before resuming or starting to bill
me for regular monthly payments or Finance Charges.
1a. NNANCE CHARGES. If I do not pay the New Balance in fun by the
due date, a Finance Charge will be added to the account or the cut.
rent monthly billing period There will be no Finance Charge g the
New Balance is paid in full each month. The Finance Charge will be
the greater of: the minimum Finance Charge or an amount deter-
mined by multiW - the Daily Periodic pate of .0576% (corre-
sponding ANNUAL PERCENTAGE RAT of 21%) by the ;h
Balances (inductug new purchases) and adding together c
Finance Charges or each day in the billing period. FFoor r
PR: The daily periodic rate is .0559% (corresponding ANNUAL
PERCENTAGE RAT of 20.4%).
16. MINIMUM FINANCE CHARGE. There will be a minimum Finance
pCha c $.50 br soli billing period in which a Finance Charge is
17. Fi?TO DETERMINE THE DAILY BALANCES. To determine each
days Daily Balance SNB will take the beginning balance on the
account each day (including any unpaid Finance Clherges--except in
PR), add any new purchases. late payment charges, returned pay-
ment charges and insurance charges, if any. and subtract any pay.
ments andcredits.
18. NO ANNUAL FEE.'
19. LATE PAYMENT CHARGE. If I fail to pay a required minimum pay-
ment by its due date, SNB may charge and f agree to pay a late pay-
ment charge of S20 n my balance is $50 or more, or $10 If my bal-
ance is less than $50.
20. RETURNED PAYMENT CHARGE. H I make a payment that is
returned unpaid for any reason. SNB may charggee andl agree to pay
a returned payment charge of $15.00. At its option, SNB will assess
5
3 is riot obligated to but may, in its dis
titexceed my credit limit from time R
final' requested e SNB to pa!
ari
:Ie on my
account whetliier uuppt to 0
Thmy request, at tide rreeq es d(ar
a user, or w)tout request
LL TAKE A SECURITY INTEREST
SNB a security interest under the
ch item Of merchandise purchasec
its affiliates and licensees, to ME
re only the rohaW price of tha
ake Payments as agreed, the sear
,sess the merchandise which
'es! h - tporoaaensy loss or damage
Is paid.
received "wit' II be deof deternriirig
emed to apply
e, returned nt charges or
the tlur?
account
for lade. and then o Pay for any late
o rr to my account on the same
kh-k Priced ilern(s),or as
IN and
once with laws of l will be the State of
ardless of where I live or where i
hws Of my state of residence win
rted herein- This agreement is
do under the agreement win be
its and conditions of this a0ree-
m is
as a
will be deemed to be residents
extent applicable, the provisions
Ill of the Rehab shag in Ssales 10
1 et seq., shag apply.
designated authorized user. S
crebon, authoriza purchases i
time. I agree o Pay such ch;
anoints in excess of my ore
responsible for ail charges in
es .my credit limit and
authorized bar gears includi
. SECURITY INTERES
9 T S {
NB
IN ALL PURCHASES. I grar
Uniform Corimencal Code in
from Sears. Roebuck and Cc
extern permitted by law, to se
item of merchandise. If I do col
errallows SNB to rep
Paid or in hA. I ar
to merchandise until
the
10. APPLICAThnu nit: b....- ,
hr 51 10 Pay arty unpaid insurai
Finance Charge(s). and then o I
in the order in which they were
charges. If more than one item is
clateZ PPaK will apply fors
if. G VERNI G LAW. This agreef
erred by and interpreted in acrD
Arizona and the United States, n
use a000unl except that the
entered into in Arizoonna andl c
extended from Arizona. r gAenn the to
ment (including ce chaand the fannrge,
vision la
an t Dugs) are deemed to be in
tiles finance dharg This,
Revised Statutes 44.12ps j?l, (0)
or provision of this agreement its to
wmake aany on or ther term or pr0?o
of the slate of Arizona. In CAaddiressi
, to ev
of the Unruh Act, Cal. Civ. Code §1
the extent applicable, the provisior
Ad, N.Y. Personal Fynno h - -
r W-f31' !r9 paYrnenl is nit honored, evert i n is paid
21.?„??S .l).my, defautl SNg may
Pon sonable en0meys fees, collection Costs (inCludi expens charge rm a.
incurred in realizing on a security interest), and court costs where
Pefnitfed by law in the state where I reside. Unless limited law,
?
?reasonablee attorrteys lees will be considerEy to be 35% of n by cunt
. In the an mY amount when It is referred to an atomey for
cclf ding ?
krwatg states, anort?eys lees may not exceed:
? and SNB
OK 15% of the unpaid debt, LA 25% Of the unpaid debt. In
balance emay ff ? attorney's lees when the unpaid
• . • •
22. PHONE CALLS.- SNB may can meb? telephone regard
this
ing I agree that SNB may place such phone cans ?lecllorpd MOM MI p tC boM May to and
rs between SNB saagssNogdates?var?q ne for
23. CReDrI" rnvt571GAoTI0N ?t Y URE OF It pgMAT10 or
SNB has the ' to irnes i:e my credit, employment and r cor e
records, to I" aedrt references, to
account to bureaus and other Interested parb
the I ,.!1%tderstge
that a consumer report prepared by a consumer reporting agency
may
obtained at the time I agl rtry
account is e to be
askepprov?d at arty time ° areas r. f h amdunt the right at
wiry
tim
SNB whener a report was obtained and, n so, to have
S
ing NBgfuurrtniiissh mepwrenphathe name and address of the consumer
agree a
armern that 1 negafive report reflecting on by?credit ire orde"' " s
submitted to a credit b agency. I .tffy SNB by felt
phone at 1.800.347repor of belleve SNB as reported h iea
rate Informatton regarding nlY account to a eredry repornrrg
24. I
and its IAT1ON SHARING I FAIR CREDIT REPORTING ACT
.. (nnduding ad =ticticin obta nedrsfrom scedn Information reporting about me
'°` amorig themselves and with companies doinrgg business fa SNB dx
affiliates. After Sept 29.1997, I may prohtblt that sharing of auat
Inforrrutbn (except for the sharing of information stout trans.
actions a experiences between SNB or ns affiliates and me) by
= . corriacUng S BN at 1.80D347.6480 and rnaldng a squeal
t
25. EVENTS OF DEFAULT. I will be in defauft of yys a greerrlent
one OOf the te blowing events occurs: La) I do not make the required
payment on the account by ihepayment due date; ) I
vide SNB withany false oi misleadng presignatines the credit application eaters tickets or other documgnts and tnstru
rrtertfr or c file or someone else tees on my behalf a petition under
the lederai bankruptcy code or any state stahde; (d) SINS
receives inbrmation or unit
that I am ur"i
"SO
terms or conditions of this agreement me) SNB recei es iperform nformation
from third parties, induding credit reportg agenaes, which indicate
a Serious delinquency or charge oft against me with other creditors;
or (1)111 become the subject of apnachrnern, foreclosure, repossession,
ENnFORCEM or
N If I d
26. L etauft, NoBceed (su bject to terminate or suspend nry credi
t (' aQWidade )
Mange the terms of my a m runder this agreement
cphaymnryylemmmiee aatcclourad balance k?todr?wW?traq? all a ?? wpa o
27. MIA; TO ENFevORCE-19-NO T WAVIER -,ii fall. or OelaY by
SNB in enforcing strict performance of this agreement indtrdirtg but
not krthited to, accepting late or partial pa a, Shan riot be con-
sidered napsry?%vaver d any of the terms of bus agreement or any of
28. WAI?KOf"LIEN ON DWELLING. SNB up aarrnry
or acquire arty lien which SNB ht be erg bcalry rod
law on rruhYd principal dwelling. This not apply to alien treated by
29. aN4S IREMINES IN EVENT OF DEFAULT. I in my
obligations under INS agreement, SNB utilkedebarry Aend ap
remedies to which if is entitled bi, ?l?aw; SN? may also refer my
account to a collection agency, or 5iu'??
30. CHANGE OF TERMS -CANCELLATION.As? -
has the right to change arty term or part of this agreement, ixAaudrr0
the rate of Finance Charge, applicable to cu"M and topes bat
ances. SNB will send me a written notice of any such changes when
required by law. SNB also has the right to cancel this agreement as
it relates to future ? purchases or other charges at any time. I agree to
31. FkANGEc0RENB upon notice of such cancellation.
SNB. Elf urn
my residence, I wiP irdorm
32. ASSI®F ACCO
RIGHTS. I understand this
under this account may be s
itor without further notice Y
required by Federal laws
have against SNB and such
34. LlAlkfY FOR UNAUTH`%,
that occurs -after IInno6y SNB of
use. I mull give notification frrv
theft or posslola unatNarized u
address indicated on my Perim
And use of
mmyy
accoW 1.
35. NOTICES TO BUYERS:wdl
MENT BEFORE YOU REAnit
BLANK SPACES. 2. YOU I
THE RIGHT TO P AYR N AI
DUE. 4. KEEP THIS AGRI
LEGAL RIGHTS.
36. CA-A TRANSLATION OF THI
DEf LANGUAGE CONVENIAO EN EL U
DISPOSICION SI LA SOLK7TA
37. CT-UNDER THE t aw WNh -
s
7
I H
AGREEMENT. T-RETAIL INSTALLMEPIT CONTRACT AVE RECEIVED A COPY OF THIS ACCOUNT AND SECURITY
SECURITY AG?EEMENT; NY-RETAIL INSTALLMENT EDIT
AGREEMENT),
sbess Undeco"aliS r
the ? Information Borg ACL
b'httb
eft our rights and our resprxf .
NOTIFY US IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR BILL
t you think you bill is wrong, or i you reed more rillormation a on your bal. wrte b us on a separate sheet at drs2 yN cn y
inner where how Irani' Val bArtg Pnla nonce to-W. rte as edsoon as Pces+ble. we
e you no ildar' IM 60 which the error problem appeared Yo can ep aeM You fe first big on
not preserve your rights, tatePf torus A t>,p dortg so WE
'ol?r and ghe aoceroded ldlowM in orme0on
rarlnber.
• Desmbe the w inter and m?alus?ieo you errs.
can thelMm? believe Mere a ern era.
# You need more hbnnation, desBee
Rbout
YOUR RIGHTS AND OUR RRF Bp,nyES AFTER ereE WE RECEIVE
CRECEIVE
NOTICE
YOUR WRITTEN It by f1h. W , yO War w*m 30 days, Wass we have cpneded
a +rar? ° sorted the errs a mtplain
w'' we believe tie ba was
Cornea
Aker we receive you later, we cannot try b WOW" amour you quesion,
1 a as. We can mom to bit you for the amtup you
In- ut. Y o u d o n ot as a 6 to Payer apply any unpaid man
y.your ere Br
?
any questioned amo while
are not in t^8, but you are 50 obligated to pay tie parts a your bill riM
lf we frld that we made a mislalre on you bit, you will not haw b pay u
trance charges related to ty
any questoned amount. 0 we didn make a Ms.
YOU may haw a 60 Pay fi?ndri6e congas, and you wB have to make Up my
a etahema d of tie a1gW yell qed ypnoW a ncase we will Send YW
tai to
pay the tamount that we funk you awe we may repel you as our dDeiii not ,,
wit it
la-art; .%-YVDU .0 WM to YOU YOU 11101111111111 ID
of wjone We Flow?evWr h a 51 about PP2'we must fall
we we must
to that the meta has been 10 we ,
a I tanyaie we repot You
firialy a settled
9
M
111MOLAX van d t? nos, we can't collect the first $50 of the questioned
your bit was correct
lf you nave aSPECIA
"ev nl wRUL FOR CREDIT CARD PURCHASES yIX1
chased with a 0" card, and you have bied gomo? fafti b COrrpCti the p?
llmwlhuL or methilwa the right not b pay rte remaining amount due on
AT SEARS YOUR SATISFACTION IS GUARANTEED
If YOU how a b&V error question
him You phone u . HBowiyeniwa, U on wish b fork Wmerdawe d be happy to
under Vie Fair C" You ge of n
ghts
ntckrde your name aocouif AcYW rout write us on a separatersheet,
Suspected error arid Whly titatwot mei.f b address shown on your cirri
nh
IMPORTANT CREDIT TERMS
You tsetse chaarige required to Wass you uetlhe ? and are rte required to pay any
Annual A+r°enfe9e Ross The Ne•lal penceritage rate is 2M
ttiumrn France Chharge A e
Lew PPaymert teas 520.00 i my Instance is 550.00 or greater,
and $10.00 f my balance is kris then S6D,gg,
Grace Period to Repay BWM y? bef eubeing dnagada
Balance Caliculation Method new Aveiat;e Balance meshed fatciirarg
Anard Fees None
10
- PROTECTION OF BUYER'
» or any interest or amount owe
assigned by SNB to another cre(
0 50, ft notice below, which i
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-02254 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SHERMAN ACQUISITION II LP
VS
WITTER CARLA E
VID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CARLA E
the
DEFENDANT , at 1918:00 HOURS, on the 4th day of May , 2005
at 27 SHORT LANE
SHIPPENSBURG, PA 17257 by handing to
CARLA WITTER
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 13.32
Postage .37
Surcharge 10.00
.00
41.69
Sworn and Subscribed to before
me this 9 w day of
J Gar; ti A. D.
TPiiothonota y J
So Answers:
R. Thomas Kline
05/05/2005
WOLPOFF & ABRAMSON
By: I G
2
Deputy Sheriff
Curtis R. Long
Prothonotary
office of the Vrotbonotarp
Cuntberlanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
OS - ,;? 25 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square 0 Carlisle, Pennsylvania 17013 - (717) 240-6195 - Fax (717) 240-6573