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Home My WebLink About05-4453ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No, 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Defendant(s). /257-/171 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, AZ 85216-6508 Plaintiff, V. HOLLY KLINE 29 East Main Street Newville, Pa 17241 CIVIL ACTION COMPLAINT AVISO NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you most take action within twenty (20) days alter 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 many 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 TEAS PAPER TO YOUR LAW YER 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. Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. OS -.41,gS'3 U.(, l£ Le hart dernandado a rated to to cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene vema, (20) dial de plazo al panir de 1a fecha de la demanda y la notificachm. Hace fatta asentar mra comparencia escrita o en persona o con un abogado y entregar a la cone en forma escrita sus defensas o sus objeciones a Ins demandas en contra de so persona. Sea avisado que si usted no se deftende, Is cone torrent medidas y puede conNnuzr Is demanda en contra soya sin previo aviso o notification. Adernas, la torte puede decidir a favor del demandame y requiem que acted cumpla con Indus las provisions de esta demanda. Usted pnde perder dinero o sus propiedades a arms derechos importantes para usted. LLE VE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO THINE EL DMERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAIO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, AZ 85216-6508 Plaintiff, V. HOLLY KLINE 29 East Main Street Newville, Pa 17241 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 65 - yys3 CIVIL ACTION COMPLAINT I . Plaintiff, Ford Motor Credit Company, is a Corporation with its place of business at P.O. Box 6508, Mesa, AZ 85216-6508. 2. Defendant, Holly Kline, is an individual who resides at 29 East Main Street Newville, Pa 17241. 3. At all times relevant, the Plaintiff was in the business of loaning money on motor vehicle installment sales contracts, including but not limited to the note signed by Defendant(s), hereinafter more fully described. 4. On or about 12/29/2003, the Defendant(s) entered into a written Motor Vehicle Retail Installment Contract, (hereinafter referred to as the "Contract"), for the purpose of obtaining financing in the amount of 22,792.48 at an annual percentage rate of SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-04453 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS KLINE HOLLY And now ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:25 Hours, on the 29th day of January , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , KLINE HOLLY , in the hands, possession, or control of the within named Garnishee MEMBERS FIRST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to ASHLEY HOECK (RECP) , personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: So answers: Docketing .00 Service .00 ??''?+?C ?49!t- Affidavit t .00 R. Thomas Kli e Surcharge .00 Sheriff of Cumberland County .00 00 01/30/2007 Sworn and Subscribed to before me this day of B Deputy Sheri f A.D 12.23%, in order to purchase a certain motor vehicle, 2003 Ford Focus more particularly described in the Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and marked as Exhibit A. 5. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $509.47 for a period of 60 months until the loan was paid in full all as is more fully set forth in the Contract. 6. Defendant(s) made monthly payments until 8/30/2004, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 7. As a result of the default by Defendant(s), and pursuant to the terms of the Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to the Defendant(s) giving the Defendant(s) the opportunity to redeem the Vehicle as well as notice of the sale date. A copy of the notice of repossession and notice ofsale date are attached and marked as Exhibit B. 8. The Defendant(s) failed to redeem the Vehicle and the Vehicle was sold at auction with a credit given to the Defendant in the amount of 6800.00. 9. After providing the aforesaid credit, a balance of $14609.95 was still due and owing, and a notice of the deficiency balance was sent to the Defendant. See copy of the notice of the deficiency balance attached and marked as Exhibit C. 10. Pursuant to the terms of the contract, Defendant is required to pay all amounts due and owing, including any balance that may remain after the sale of the vehicle. The Defendant failed to do so. Defendant is indebted to Plaintiff for the balance of $13469.89. 11. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to 1029.04 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $14498.93. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $14498.93, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. Respectfully submitted, MAUR E I T EDLEMAN, P.C. THOMA . DOMINCZ K, ESQUIRE Attorney for Plaintiff VERIFICATION I, THOMAS R. DOMINCZYK, ESQUIRE, verify that I am the Attorney of record for Plaintiff, FORD MOTOR CREDIT COMPANY, and duly authorized to make this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A, §4904 relating to unworn falsification to authorities. BY: ARE DATED: <? 12 J (65- PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT . DATE 12/29/2003 9oYw (rw Co9oY.4 Name W Add"ss Iulaodlle Ceunry slid 21p Grda) CREdrOR ladler Nana am AENaaa) -fDEC 3 0 2003 pc/ 4020YCOSEYITOWN RD 6320FCARLISLERPIKE J?I ?ll? 0 p GREEN CASTLE FRANKENHEINER PA 17225 NECHARICSBURG PA 17050 tlNalles a bNee leI Cm11 ar es wadA NEW 106 (FOCUS I I 3FAHP37393R193498 I NO( Cwmnsaal °APlmrww YOU MAY OBTAIN VEHICLE INSURAN FROM A PERSON OF YOUR CHOICE 7. Cash Rice ...... ........... _ ............... ............. ..... § 24094.00 (y) 2. Down Psyn and dit d P R b A d d 3000.00 S to cre or .... _..... _._ ............. yAe vamteu 0m em Thir oomalyD " - ' - A Aw 375 64 Tnesln ZIxIZ hUxO T$ S 35.06 v.wwuaa Q- .ns A.w.a oao Tow Down payment _..._.._.._............ _.... _......... ...... ....... . .... $ 3335.06 (M 2. Unpaid BaMnee of Cesh Prime (1 mire 2) ....... ......... _._........ . _._ f 20758.94 (3) 4. Amouma Paid on your behalf (Sow, may m ratelning a portion of man amm rrs) To Insurance Companies for N/A $ Crealf Lift Insurance (to, Leon of oomaaq ..._........ _..... _. N/A $ C II Disability maurance (for ?^^ of cuntmm) .............. "r^ rrerm^2fi-mntla(Estinme)1$ N/A To Pubre OMclam (p V Ika?naon 1 6.00 . SNa IS ; 26.0 n(3 N/A) la d .c,r0 .), 8 , 6 "p e o 00 for filing fees IF (M)le twome (not In Cam .00 Price) $ 266.04 299.54 Taw FEDERAL TRUTH-IN-LENDING DISCLOSURES ANNUAL FINANCE a Amount TOG( of Total Sale PERCENTAGE CHARGE Financed Peylncrlls Price RATE The mlw on cum Ttw amount W rma wnwmt Tne mm Con .en "r"aided m Will have w owe ao.a m 1 11 payment Sayaaule Number of Amount of Each When Pai mmta X4.1 P me Piymam are do your payment Schedule 59 § 509.47 (monlhN smNng) A be: 1finml It 509.47 0112812004 tiwan : Youm fle The 1 not You Airy challBe F ilia wnlra'd'Sm?um ba In wMYp eel i nm1MY?R. Rte. ?93?2 hive to Pay a canary. on of each payment reuMd nm" aunt or $W.00 Whmnr Is law. M aehNJe being feraacad. euon on aacudry In ere" nonceNn b.mre me echW.10 time. alM de eel mar n elumnp lalderaiewn gone leceMtl hor Me .10,1&. CLOSURE you eel the CreMlar YOU ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO BE BOUND BY THE ARBITRATION PROVISION ON THE REVERSE WE OF THIS CONTRACT. NOTICE TO BUYER Do not sign this contract In blank. You are entitled to an exact copy of the contract you sign. Keep N to protect your legal rights. Buyer (and Co Buyer) acknowledge that (I) before slaying this contract, Buyer an Co-Buyer) received an- reviewers a true arecTcomplately flliad in Copy of this Contract and (tl) at the three Of 2 nin (his Dontnot, Buyer (and Co-Buyer) Secsslv-W a rue an comp e . y filled in copy of this contract >P 116 r eo ? Covell. x no pNw AeNOua 4 "Coned me In a aWerW eYMPwleyaaatbyxpwale BM4Na?YraaaQqOaUMe..ke aW ?11llPFFERiY FORD $abarXmPl. Rm create CemPwy. Moore"m rlnae.mo-e aaa ma M MACK rrON AImI1MNAL"EOIIXra PA YOU ARE NOT REOUIRED TO OB CREDIT LIFE, CREDIT DISABILITY OTHER OPTIONAL INSURANCE CONTRACT WILL NOT INCLUDE I UNLESS YOU SIGN AND AGREE TO THE PREMIUM. THIS CONTRACT DOES NOT INCI LIABILITY INSURANCE COVERAGE BODILY INJURY AND FROM DAMAGE CAUSED TO OTHERS. OCredR LaeJIIA Insurer MIA $ Rornlum Insureds) Signature Credit a Cusabony NIA Insurer NIA $ Premium insured S' velure ? N/A Y/A Other Optional Insurance Tenn N/A $ _ e/A Insurer Premmm l na ure Cresb LN. mm frank WYa imu"rce M fa tia tam a tlm conaacl. w"or"d and mw"3s an abeam In a esrme m wasem en yaen to you red". You mutt Inau" the "wale. N a rd"ga Y ~ below Rio C"dhor WY try to buy me cormaelaeeaa wIII eel an Ma ca me .al?ua not Ca whltla at now, of Was, but not rnme than me It.M of We paltry. ? Comp"Mnaive ?$ Y/n peducpbN waken ? Fie- Theft molned AdEwom Cowmge ? To," arol labor ? Twin N/A Moms (i Son ma) Ramlumr NIA 4rcaN cancellation whew AGdamum (OPtiweg X mb bin Is chm ad you Hew Wrdased . "N ocnpamY J M mmuseto dweftwdr The lrms I MYmereNatlMa EnAddmO®u?nn wNN k ymry?oaae eN ail mead. rn.?.. ra m axr an"mmn d raml?RUmaE undwmsns i. tla Rembatlm Program No. pUEST10NST i 4N8 PLEASE CALL US AT 7.000.727-7000 Visit us at xow.foraeraak.eom Or401 ORIGINAL --- - -- - - - - ------------ ---- -- - - - --------- - ------- a. 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PA 15535 Date o(Rpasesalm 11-22-2004 Date Of NOtlca 00%d cwumt 11-23-2004 12-29-2003 Account Number. 0358318 Is Buyer HOLLY KLINE cobuyear DESCRIPTION OF PROPERTY Year I Make 2003 FORD 0 New ? Used Vehicle Identification Number. 3FAHP37393R193498 Model FOCUS Body 5DR NOTICE OF OUR PLAN TO SELL PROPERTY We have your properly described above because you broke promises In our agrserrent. ?% PRIVATE SALE: We will sell the property described above at pdvab sale eor4g" after 15 days fran the Dab of Notice shown ebow unless redeemed by you prior to such sale. ? PUBLIC SALE: We will sell the property deacrlbed above at public sale to the highest bidder on the data below (or any adjournment date). The sale will be held as follows; Dots of Sam Time of sale place of Sale You may stand the sale and bring bidders t you want. NOTICE OF REPOSSESSION The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by law) will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. If we get more money than you owe, you will get the extra money, unless we must pay it to someone else. You can get the property back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. See How To Get Your Property Back for an itemization of amount Owing. To learn the exact amount you must pay, call us at the telephone number above. If you need more information about the sale call us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you owe us, you may call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money unde your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent With this notice. The property is presently stored al: MANHEIMS AUTO AUCTION NHEI AU AUC A HOW TO GET YOUR PROPERTY BACK To get your property back, pay us #us amount by certiflad check or money ado before the vehicle is sold, Unpaid Balance $ 21,001.26 Plus Costs: Repo Expenses $ 125400 Plus Late Charges Lass Finance Charge Rebate Lass Insurance Premium piston, TOTAL g 10.19 $ 21,226.45 (Plus expenses incurred if default a the time of repossession exceeded 15 days and less rebels received efts the data of this notice.) Your propertywoni be sold until 15 days after the date of this notice at the FARUEST. Amer that you can side get i back shy time before it's actually sold. If you do, wall have no furtar claim m R But the longer you wait, the more casts (Including ropers) you may haw to pay. If you haw any questions about this, please call W. ? The property has been (or will be) returned W. (dealedoriginal creditor) Under our agreement with your dealedcriglnal creditor, the doela/origmal creditor is to sell the property and pay you any money let over. If you owe money after the sate, you will pay it to to dealmoriglnal creditor. ? PERSONAL PROPERTY: Any ceremA property found in the vehicle may be reclaimed by you within the next 60 days a, in accordance with able law, by contacting this o fins Thereafter, to personal property shall be disposed of accordingly. ? Creditor has aselgne l to is qualtbd Intermedlary (OI Exchange. LLC) Its dghts (but not is obligations) with respect to the flab of each which listed above. PAYMENTS: All payments to us must be by certified check or money order. MILEAGE DISCLOSURE: If you are aware that the mileage reflected on the whicb's odometer Is not accurate tar my reason, please contact us sothetwe can acarahfy rpm the whlcle's mileage. INSURANCE RIGHTS: If you donl want to get your property back, cell the Insurance company or the desimbiglnal creditor to make sure tet shy insurance no been cancelled. You haw a right b get aadt far all prewJum refunds. SHERI GEORGE HIW 11961137 Jen M P? .eeaen. my Non a ewe. CUSTOMER/CUSTOMER FILE PdMM In UZA. Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 210456076 800 6770730 DATE: 2005.01-13 00072 HOLLY KLINE 1816 FLINTSTONE CREEK RD CLEARVILLE PA 15535 STATEMENT OF SALE Account Number: 035831696 The following property has been sold. Year Make Model 2003 FORD FOCUS Balance owing on your contract Vehicle Identification Number: 3FAHP37393R193498 Deduct: Finance Charge Rebate Balance less Finance Charge Rebate (1 - 2) Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Other: (1) $ 21,101.45 (3) $ 21.101.45 (5) $ 14.301.45 (9) $ 14609.95 Deficiency" Surplus" (10) $N/A The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses & interest added to your account (debits). Surplus' or Deficiency" " If the sale resulted in a surplus, a refund for the difference will be mailed to you. " If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for payments shown below. For additional Information call or write: Ford Motor Credit Company P.O. BOX 6508 MESA ARIZONA 85216.6508 (800) 732-2264 Mail deficiency payment to: Ford Motor Credit Company DEPT 194101 P.O. BOX 55000 DETROIT MI 48255-1941 (2) $ 0.00 (4) $ 6,800.00 (6) $ 308.50 (7) $ 0.00 (8) $ 0.00 FFH I INN U1N4 Previaua edkbM may lpT be uaed. F LV) r 1 CsJ SHERIFF'S RETURN - REGULAR CASE NO: 2005-04453 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS KLINE HOLLY RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE KLINE HOLLY was served upon the DEFENDANT , at 1752:00 HOURS, on the 7th day of September, 2005 at 29 EAST MAIN STREET NEWVILLE, PA 17241 HOLLY KLINE by handing to 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 9.60 Affidavit .00 Surcharge 10.00 .00 37.60 Sworn and Subscribed to before me this day of S7, A X06,'- A.D. Pro nota So Answers: R. Thomas Kline 09/09/2005 MAURICE & NEEDLE By: ep ty Sheriff MAURICE &NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FORD MOTOR CREDIT COMPANY Plaintiff V. Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-4453 HOLLY KLINE Defendant(s). PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the verification of the Plaintiff, Ford Motor Credit Company, for that of the verification previously filed. Respectfully submitted, MAURICE & NEEDLEMAN, P.C. Date: jb?3?DS Attorney for Plaintiff CERTIFICATE OF SERVICE I, Thomas Dominczyk, Esq. hereby certify that on this date I have caused a true and correct copy of the foregoing Praecipe to Substitute Verification on behalf of Ford Motor Credit Company, to be served by regular, first class mail, postage pre-paid upon: HOLLY KLINE 29 East Main Street Newville, Pa 17241 Respectfully Submitted, MAURIOh4c NEEDLEMAN, P.C. Thomas Dor Attorney for DATED: /&/316 VERIFICATION I, ay?Tttter verify that I am the Authorized Representative for Plaintiff, Ford Motor Credit Company, and are duly authorized to take this verification on its behalf, that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unworn falsification to authorities. BY: AAL_4CO DATE: `?? aGC1S HOLLY KLINE Our file no. 953 48063000000035831696 ?, ?? - c> ? ? , .-? - =r,,:?, -? ?? r -; -, ' ?p __ , tIJ MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff V. HOLLY KLINE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-4453 PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: No answer having been filed in the above Civil Action, kindly enter Judgment in favor of Plaintiff, and against Defendant, HOLLY KLINE in the amount as follows: Principal Amount $ 13469.89 Interest to Date $ 1669.93 Court Costs $0.00 Attorneys Fees $ 0.00 TOTAL $ 15139.82 MAURICE & NEEDLEMAN, P.C. BY: Attorney for ESQ. MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (ZID)/aY-/1D4 FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF Plaintiff COMMON PLEAS V. I CASE NO. 05-4453 HOLLY KLINE Defendant(s) O Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount 0174+5- z on O A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. 0 Prothonotary/ClcrV by:J If you have any questions regarding this matter, please contact the filing party: Name: THOMAS DOMINCZYK, Esquire Address: Suite 935, One Penn Center at Suburban Station 1617 J.F.K. Boulevard Philadelphia, PA 19103 Telephone No.: 215-789-7154 (This Notice is given in accordance with Pa.R.C.P. §236) MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff V. HOLLY KLINE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-4453 AFFIDAVIT OF MAIL SERVICE STATE OF NEW JERSEY COUNTY OF SOMERSET SS. THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law, deposes and says that she is an attorney at law and that on 10/21/2005 (date) he/she mailed a written Notice of Intention to File the Praecipe to Defendant, HOLLY KLINE, at29 EAST MAIN STREET, NEWVILLE, PA 17241 by certified mail, article nos. 7005 0390 0006 4278 6014. Copies of the receipts evidencing said mailing are attached hereto. A copy of the signed green card evidencing receipt of said mailing is attached hereto as well. ESQ. SWORN TO AND SUBSCRIBED before me this -?? 1 0 1(b 1,(c l V,200 ?. ) otAtY P ubtiV KYMBER0 L fAPERA A NOTARY PUBLIC OF NEW JERSE'`' MV Cammission Exoires 11/01/2009 Attorney for Plaintiff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff V. HOLLY KLINE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-4453 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 10/21/2005 to Defendant, HOLLY KLINE, against whom judgment is to be entered after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A copy of said Notice dated 10/21/2005, a copy of the receipt for certified mailing to the Defendant and affidavits of service of said notice are all attached hereto. BY: P.C. 'I HOM'AOMINCZYK, ESQ. Attorney r Plaintiff Sure 935, One Penn Center 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215,665.1133 fax 215,563.8970 www.mnlawpc.com Donald S. Maunce Member NJ Bar Board Certified Creditors' Rights Law American Board of Certification Joann Needleman Member PA & NJ Bar Thomas R. Dommcr/k Member NJ & PA Bar a d .. M1 N Postage October 21, 2005 -11 0 7 C3 Relum RBCBI 1c = q r (Endore O Restricted Delivery Fee D' (Endorsement Requaedj VIA CERTIFIED & REGULA R MA o roral postage & Fees HOLLY KLINE o nt To 29 EAST MAIN STREET C3 NEWVILLE, PA 17241 `` orPOa; aPOB oxNb RE: FORD MOTOR CREDIT COMPANY V. HULL Y &1 CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 05-4453 Dear HOLLY KLINE: Enclosed please find a ten (10) day notice of default which is self- explanatory. This is being served upon you due to your failure to respond to Plaintiffs Complaint served upon you on 09/07/2005 . Unless an answer to Plaintiff's Complaint is filed with the Court within ten (10) days from the date of this notice, a default judgment may be entered against you. If you would like to discuss a resolution to this matter, please call our office at 908-575-0220 ex. 21. Thank you for your prompt attention to this matter. I ery truly yours, COMPLETE ? SECTION COMPLETE THIS SECTION ON DELIVERY Complete Items 1, 2, and 3. Also complete A. Signature _ Item 4 if Restricted Delivery is desired. ? Agent X - ? Pint your name and address on the reverse I rl3-e- ? Addressee so that,we can return the card to you. Attach this card to the back of the mailpiec e, B. Received by (Printed Name) C. Date of Delivery 10-9d-0 5 or o the front It space pennfts. - , ' ie: D. s delivery d m fmm item 17 ? Yes If YES t li ? N d b l dd , en er o e very a e ow: ress ? 5?. a l( w o ll 11 N* l A 7 i? 1 ?L-r 9.3ervlce Type ?( mfl G M ll ? E M `- " , ,a e e eal xpress r ^ 13 Regratered etum Receipt for Memhendiie I ( ?.Ineured Mall O C.O.D. ,. 4. Restricted Deliver)? (Extra Feel O Yes AMde Number 7005 0390 0006 4278 6014 7mnster nom service neap Forth 3811, February 2004 Domestic Return f3ecdpt 102595-02-ht-1640 PT TO COLLECT A NED WILL BE USED i COLLECTOR Attorneys for Plaintiff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 /25Y-/1J1 CUMBERLAND COUNTY COURT OF COMMON PLEAS FORD MOTOR CREDIT COMPANY Plaintiff CASE NO. 05-4453 V. HOLLY KLINE IMPORTANT NOTICE TO: HOLLY KLINE DATE: October 21, 2005 29 EAST MAIN STREET NEWVILLE, PA 17241 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE AN ANSWER IN THIS CASE. UNLESS YOU TAKE ACTION 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 RIGHTS TO DEFEND AND THEREBY LOSE 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 LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MA & NEEDLEMAN, P.C. BY HOMAS DOMINCZYK, ESQ Attorney for Plaintiff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff V. HOLLY KLINE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-4453 CERTIFICATION OF ADDRESSES It is hereby certified that the parties have the following addresses: Plaintiff: FORD MOTOR CREDIT COMPANY P.O. Box 6058 MESA AZ 85216 Defendant: HOLLY KLINE, 29 EAST MAIN STREET, NEWVILLE, PA 17241 NEEDLEMAN, P.C. BY: ESQ. Attorney for Plaintiff 4 .. , MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF Plaintiff COMMON PLEAS V. CASE NO. 05-4453 HOLLY KLINE Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF SOMERSET SS. THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law, deposes and says that she represents the Plaintiff in the above entitled case and that Defendant, HOLLY KLINE, is over 18 years of age; the occupation of Defendant is unknown and to the best of Plaintiffs knowledge, information and belief, Defendant is not in the military service of the United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. MA BY: SWORN TO AND SUBSCRIBED before me this x 2iay (of i"(M t a 1, 00?. -'(171 j P?ota{ 4ubll KYVIBERLY= :-,uPERA A NOT ARY PUBLIC OF NEW JERSEY my Commission Expires 11/01/2008 ESQ. Attorney for Plaintiff lJ Z ?i i r.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ? r CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: twD 1 OTU (%1P (l vs. f-tvily ??i,??cn?anf J mars ?s? WIWI Cnvlait (Mcp ( ) Confessed Judgment ( ) Other File No. 2 3- 443 Amount Due /,5d3Q. 0 a Interest ' JJsl yto ? l5/ SA Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of uma flanA County, for debt, interest and costs, upon the following described property of the defendant(s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of h jmo r u't.rrt County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) am any ao orzfxmi am fir nom in mr nn nv - itL ML Mnaarff x 6ilgr %hmmi OnW and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). 0 (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date 3 - S- 0(0 Signature: Print Name: Address: Attorney for: Telephone: Supreme Court ID No.: H4]b (over) 1_. n r; ptq q AJ 2Z6-70_ SPA 7L L rn r: r ?COCC c- 1 '`t7 r t? r GD ?. c WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4453 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT, Plaintiff (s) From HOLLY KLINE, 29E. MAIN ST., NENWILLE, PA 17241-1110 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS IT FEDERAL CREDIT UNION, 1166 WALNUT BOTTOM RD., CARLISLE, PA 17013 - ANY AND ALL PROPERTY AND ACCOUNTS IN THE NAME OF THE DEFENDANT GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $15,139.82 Interest 3/8/06 - $151.82 Arty's Comm % Atty Paid $120.10 Plaintiff Paid Date: MAY 11, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs CG IS . Prothonotary By: Deputy REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: 935 ONE PENN CENTER PHILADELHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7151 Supreme Court ID No. 74276 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Attorneys for Plaintiff Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 15) "/89-7151 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, AZ 85216-6508 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, V. HOLLY KLINE 29 East Main Street Newville, Pa 17241 Defendant(s). Case No. 05-4453 PRAECIPE TO DISSOLVE/WITHDRAWAL GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve and withdrawal the garnishment execution against Members 1st Federal Credit Union, forthwith. Date:05/30/06 c b S7 -r, - SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-04453 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS KLINE HOLLY And now DOUGLAS RUZANSKI ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0009:38 Hours, on the 24th day of May , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , VT TTTT" TTlIT T V , in the hands, possession, or control of the within named Garnishee MEMBERS FIRST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to ERIC HESS (ASST BRANCH MANAGER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to His true and made Sheriff's Costs: So a s%I'aaC?? Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 00? ?r?- G?3dle4 05/25/2006 Sworn and Subscribed to -2w before me this day of By eput her' A.D Maurice & Needleman, P.C. By: Thomas R. Dominczyk, Esq. Identification No. 85248 250 Route 28, Suite 203 Bridgewater, NJ 08807 908-575-0220 FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS V. NO. 05-4453 HOLLY KLINE CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiff, Ford Motor Credit Company, certifies that: 1. A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoena is sought to be served. 2. A notice of the intent, including the proposed subpoena, is attached to this certificate. 3. No objection to the subpoena has been received; and 4. The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date: October 23, 2006 QUIRE MAURICE & NEEDLEMAN, P.C. BY: Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7155 FORD MOTOR CREDIT COMPANY Plaintiff, V. HOLLY KLINE Defendant(s). Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-4453 NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Plaintiff, FORD MOTOR CREDIT COMPANY, by and through its attorney, Thomas R Dominczyk, Esquire, intend to serve a subpoena, identical to the one that is attached to this notice and which will be sealed by the Prothonotary. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Respectfully submitted, , P.C. DOMINCZYK, ESQUIRE Date: 9 Lz'/4 _es? No. V. S SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 T0:P YA i? kLi?&-V?o (Name of Person or Entity Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: La any and all at: y regards to .o and in You may deliver or mail legible copies of the documents or things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order com- pelling you to comply with it. This subpoena was issued at the request of the following person: Thomas R Dominczyk Esq. 85248 Attorney's Name Identification Number 250 Rt 28, Suite 203, Birdgewater, NJ 08807 Address Attorney for Plaintiff DATE: 908-575-0220 Telephone Number BY THE URT By (Prothonotary -Ti i i l s r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Aldt" ?PRAECIPE FOR WRIT OF EXECUTION Caption: VS. tj\- K_[,-ac, ( ) Confessed Judgment (') Other File No. d? Amount Due Interest 73{ . Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below. does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Gu ML, rICi/tC(- County, for debt, interest and costs, upon the following described property of the defendant(s) Oiro_i ?( AN (9 C1`A? ?5 11',tn-(CA re ck wtf-E, W -Fc o PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of C. km 14A L County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) ?dtir1 ?t,? Q CCU rLS ??;?? ?? z rre?- S 1 S ?C.q and all other property of the defendant(s) in the possession, custody or control of the said gamishee(s). 0 (indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date Q 1274 Signature: Print Name: Address: Attorney for: Telephone: Supreme Court ID No.: t/I il ??s m, ?? -(171? CIS ??? ??S-? (over) Z- 4c., ? ? Ln 2 11.10 0 a o? "es w W 0 ?I 'j 1 1 ? ro? 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4453 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s) From HOLLY KLINE, 29 E. MAIN ST., NEWVILLE, PA 17241-1110 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1ST FCU, 1 CARLISLE BARRACKS #46-482, CARLISLE, PA GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $15,139.82 Interest 5/08/06 - $731.69 Atty's Comm % Arty Paid $133.10 Plaintiff Paid Date: JANUARY 2, 2007 L.L. Due Prothy $1.00 Other Costs (Seal) Deputy REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 Supreme Court ID No. 74276 1 l FORD MOTOR CREDIT COMPANY Plaintiff, V. HOLLY KLINE Defendant(s). MEMBERS 1 sT FCU Garnishee CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 054453 AhSl??1'S fa INTERROGATORIES IN ATTACHMENT TO: MEMBERS 11T FCU You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default judgment against you. 1. At the time you were served with Plaintiffs writ of execution, or at any subsequent time, did you owe the defendant any money or were you liable to defendant on any negotiation or other written instrument, or did the defendant claim that you owe him/her any money or were liable to him/her for any reason? If your answer is in the affirmative, please advise the amount of money you owe the Defendant, or the amount you are liable to the Defendant. I V 2. At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? NIA 3. At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? N 4. At the time you were served or any subsequent time, did you hold as fiduciary any property in which defendant had an interest? Nl? 5. At any time before or after you were served, did the defendant transfer or delivery any property to you or to any person or place pursuant to your direction or consent, and if so what was the consideration therefor? 6. At any time after you were served, did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? N I ? 7. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax or other accounts or deposits in which defendant has an interest? If the answer is in the affirmative, please advise the amount of defendant's interest thereto at the time of the service of the writ. N I N ?\CCOW\-\- CAOUd a?,? ?+N 9, bIDOrl JP4M )QEEDLEMAN, ESQUIRE ttrnev for Plaintiff a O MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (215) -/89-/1J1 FORD MOTOR CREDIT COMPANY Plaintiff, V. HOLLY KLINE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-4453 PRAECIPE TO DISSOLVE/WITHDRAW GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve/withdraw garnishment upon Members I" FCU forthwith. Date: February 13, 2007 Res ectfully Submitted, AU CE & NEE LEMAN, P.C. Jo ee le , Esq. Q b ?-- ? ca {? R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. frs Costs: Advance Costs: 150.00 - Sheriff's Costs: 84.55 cm M-dage eting 18.00 $ 65.45 1.65 aA*ertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 01/17/07 Mileage 4.40 Surcharge 30.00 Levy 20.00 Certified Mail Post Pone Sale Garnishee 9.00 Postage TOTAL $ 84.55 ? Vol So Answers; R. Thomas Kline, El 1%b' By Claudia A. Brewbaker U F fi .b b' b ? ?{ 6'W 9001 J0 X01 -40 .0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4453 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT, Plaintiff (s) From HOLLY KLINE, 29 E. MAIN ST., NEWVILLE, PA 17241-1110 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1sT FEDERAL CREDIT UNION, 1166 WALNUT BOTTOM RD., CARLISLE, PA 17013 - ANY AND ALL PROPERTY AND ACCOUNTS IN THE NAME OF THE DEFENDANT GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $15,139.82 L.L. $.50 Interest 3/8/06 - $151.82 Atty's Comm % Atty Paid $120.10 Plaintiff Paid Date: MAY 11, 2006 (Seal) REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: 935 ONE PENN CENTER PHILADELHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7151 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary By: Deputy Supreme Court ID No. 74276 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage 1.65 Advertising Law Library Prothonotary 1.00 Mileage 4.40 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 84.05 ,/ yf Advance Costs: 150.00 Sheriff s Costs 84.05 65.95 Refunded to Atty on 04/02/08 So Answers, R. Thomas Kline, Sheriff By (I LL-FL L1 #T L031 '? Ci C v ??1 L?JI J (:N U J'V*D 4 5S5-)- ?,_ .20 ? 819 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4453 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s) From HOLLY KLINE, 29 E. MAIN ST., NEWVILLE, PA 17241-1110 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS 1sT FCU, 1 CARLISLE BARRACKS #46-482, CARLISLE, PA GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $15,139.82 Interest 5/08/06 - $731.69 Atty's Comm % Atty Paid $133.10 Plaintiff Paid Date: JANUARY 2, 2007 (Seal) L.L. Due Prothy $1.00 Other Costs Curtis R. Long, Prothonotary Deputy REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone : 215-789-7154 Supreme Court ID No. 74276