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HomeMy WebLinkAbout05-5039 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA LHR, INC., assignee ofCITIFINANCIAL NO. ()S' -SCJ3? Civ~L~8twl IN CIVIL ACTION Plaintiff( s) -vs- JASON M BOLAN Defendant( s) COMPLAINT CODE- FILED ON BEHALF OF PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: James R. Apple, Esq. P A I.D. No. 37942 Charles F. Bennett, Esq. PA I.D. No. 30541 Joel E. Hausman, Esq. PA I.D. No. 42096 APPLE AND APPLE, P.c. Firm No. 719 4650 Baum Boulevard Pittsburgh, PA 15213 Telephone: 412-682-1466 Fax: 412-682-3138 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA LHR, INC., assignee of CITIFINANCIAL NO. OS- - 5039 C;u~L~~ IN CIVIL ACTION Plaintiff(s) -vs- JASON M BOLAN Defendant(s) NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice, for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1800-990-9108 2 COMPLAINT 1. Plaintiff is a corporation having offices at 56 Main St., Hamburg, P A 14075, and as the assignee of Citifinancial, stands in its assignor's stead, and all are hereinafter referred to interchangeably as "Plaintiff'. 2. At a specific instance the Assignor sold, assigned and transferred to Plaintiff all of Assignor's right, title and interest in, and to the agreement between Assignor and Defendant. Assignor had the right to assign the agreement. A copy of the assignment is attached hereto as Exhibit "A". 3. All conditions precedent to Assignor's right to be paid under the terms of the contract have occurred. 4. Defendant is an individual whose address is 111 S Prince St, Shippensburg, Cumberland County, Pennsylvania 17257. 5. At a specific instance and request of the Defendant, the Defendant applied for and was granted a credit card by Plaintiff at the terms and conditions agreed upon by the parties. 6. The Plaintiff avers that the agreement between the parties was based upon a written agreement which the Defendant accepted by using loan to make purchases and/or cash advances. 7. Thereafter, in breach of obligations under the Agreement, the Defendant failed to make payments as they became due. 8. Plaintiff avers that the terms of the Agreement provide for acceleration of the entire balance due and owing upon Defendant's breach of the Agreement. 9. Plaintiff avers that the balance due amounts to $7,650.61, as is more specifically shown by Plaintiffs Statement of Account, a true and correct copy of which is attached hereto, marked Exhibit "B" and made a part hereof. 1 O. Plaintiff avers that the interest has accrued at the rate of 6.00% per annum on the balance due from May 24, 2005. 11. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and refused to pay the amount due to Plaintiff or any part thereof. WHEREFORE, Plaintiff demands Judgment against Defendant in the amount of $7,650.61, with appropriate additional interest from May 24,2005, and costs. APPLE AND APPLE, P.e. By: ;~~. . '.'" .., .~. a.. ;J~~' .~:;.. .:.: \':J.~f ~-" .. ..,,: l. , \":.'// _'n.. ....~.- ~~!f:> :. . ~~~;:,.:.- '.., !. ~. ...~ ~. ...... . ._-. -.'W.', ;.~ :4;"-it.. ,"~~' ..~... . ~~...~~ ~. ~1:;" ,/ cffiflnanclaJ LOAN SALE AGREEMENT THIS AGREEMENT, made this 18th day of March 2004. by and between Citifinancial . Corporation, located at 11436 Cronhill Drive Owings Mills. Maryland. a Maryland corporatio~ on behalf of itself and all of its affiliates (hereinafter referred to as "Seller"), and s,,~ CQpital .located at 1601 West Airwrt Freewav. Euless. TIC 16049. (hereinafter referred to as "Buyer'l 1. In consideration of which considerotion is to be made by wire transfer. the Seller...hereby sells. assigns. transfers and conveys to Buyer without recourse, warranty. either expressed or implied, or liability except as herein expressly set forth, all those installment sale contracts, credit agreements, invoices. indebtedness. loans. or other obligations and any instruments securing same (hereinafter referred to as "Receivables"), except iii~\tifilenThPaidboto the Selhasler in !::.)t11 oben or before ~ ~ ,,' . ";t r. '. eave pure e SIIA payment .lor all records in Citifinancia)'s possession relating to said Receivables. 2. Wirh respect to the above Receivables, the Seller warrants the following to be true in material respects: a. It has complied, to the best of its knowledge and belief.. with applicable federal. state and local laws, and regulations relating to the making and collection of the Receivables up to the date of the relevant sale. b. It owns good and marketable title to all of the Receivables, nee and clear of all liens and pledges. c. It has full power and authority to sell. assign. transfer and convey the Receivables to the Buyer. and all other necessary proceedings on the part of the Seller have been duly taken to authorize the sale. d. All of the Receivables, to the best of its knowledge and belief. were made for valuable considerations and are now legally enforceable obligations of the respective persons shown as indebted thereon, except as may be limited by bankruptcy, insolvency, moratorium, receivership, conservatorship, reorganization or similar laws affecting the rights of creditors generally or equitable principles limiting the right to obtain specific perfomlance or other similar relief. All payments shown on the records relating to the Receivables were made on the date indicated on said records. '~CFlninA" S&P Capltallnitlals ~~~~. ;,~:::- cffiflnanclal , :... ~. ~.!f':" '~"'" :~~~' .' '". ''iii'' '.~.\r-:~ .~ .A:L.., ;f.~~ ," .:~ ;.~.. ." :~~::t' ", ..... . " 't, : . ;/ ". . 'l)-'" .'~:.;.: e, The persons shown as indebted on the Receivables have not initiated any lawsuits against Seller t and to the best of Sellets knowledge and belief. such persons have no legally enforceable rights to set-off. counterclaim, cancellation. or legally enforceable claim that the Receiva.bles suffer from Jack of considcrntio~ forgery or alteration of such person's signature, except as may be disclosed or contained in the relevant tile or documents, f. The amounts shown on the hard copy and diskette to be owing and unpaid on the respective Receivables represent the true and COITCCt net outstanding balances (principal balances only) thereon at the dates shown on diskette. Upon written notice to seller by buyer. seller agrees to repurchase for the same percentage of the net outstanding balance: that Buyer paid for such Receivables, all accounts that have, as of the Closing Date. previoUSly settled, arc under bankrllptcy protection on the date of the sale, are deceased, or ha.ve disputed the account in writing prior to the sale date_ Fraudulent accounts must be evidenced by a notarized affidavit to qualify for repurchase. Accounts must be submitted to Seller within 120 ~aVl of the Closing Date herein, Seller will repurchase accounts submitted within 45 days of receipt of the request. g. The infonnation concerning the Rcc:eivable:s and the security therefore and the person shown as indebted thereon which bas been furnished by the Seller to the Buyer is correct to the best of Seller's knowledge. h. There are no judgments, to the best of Seller'! knowledge and beliefs, against the SeUer that could become a lien against the Receivables. ?m:,. '0 -J"i!p.i.jJ. ; ~~"!: 4. ,:,.' - ;'\ ' .; ~ ' .~~.~ . ,"'....... .. s. -~. ., ~CFln.... ,.... ,-,... SeJler agrees that if any of its warranties herein are breached or if any claim or defense exists against Buyer arising out of a breach of any warranty herein. Seller will repurchase such Receivables on demand for the same percentage of the net outstanding balance that Buyer paid for such Receivables. Buyer shall not assume or incur liability for any debt. other obliaation of Seller. other than as herein provided. S&P Capitallnitialll .;;;.:.:.... .~ ~..,~: .T~~. . ""I..:,. t};.... 'I~ '. ".: '!.. ::.' '. . ........ ", ~ ~;.Lt ,..... '\;'.. .;~~;.'. ; ,_........ 1_.. ~.: ';:' ~....; . -"~ '.- .' :~. ".~.~ ~ : .~.. ~ '.... '" .'. '."1"-; . ;'~:~::". ... ,', " ,',.. .'.' . .......I..~. " : ~ . ~.~. ..' ;i., ...... . ~q':~l' ~:~t: .. . !. " . 'L' ~. tt=!~ . "''r.'', . :.~'..:.: .... cmflnanClar 6. 7. 8. 9. Buyer may advise debtors who are obligated on the Receivables that it has purchased such Receivables and Bllyer shall take that aU payments there on shall be made to the Buyer and all legal and other action respecting the Receivables in its own name and not the name of Seller. Seller hereby constitutes and appoints Buyer the true and lawful special attomey~in~fact of Seller in the name and stead of Seller, on behalf of and for the benefit of Buyer, to endorse the name oftbe Seller without recourse upon all checks, drafts, notes, powers aDd other fonDS of exchange received as payment on any of the affected Receivables, for Q period not to exceed six months following execution of this agreement. Scller further agrees that any payments received by the Seller on said Receivables from and after the close ofbusincss on ~ .... shall be turned over IUld delivered to Buyer at the time of the consummation of this Agreement. If the Seller receives such payments after this Agreement is consummated, Seller shall as soon as practical turn them over to Buyer in the form received. The purchase and sale contemplated by this Agreement may be subject to the approval of certain regulatory authorities, and if so the parties agree to obtain such approval prior to the date of closing; otherwise, this Agreement shall be void at the other party's sole option, 10. This agreement shall be governed by and its provisions construed under the laws of the state of Maryland, and Federal laws where applicable. 11. Buyer represents and warrants to Seller that: a. It is qualified to transact business and duly licensed in aU jurisdictions where necessary to purchase, bold, collect or enforce the Receivables or any amounts due thereon. b. That it has full power and authority to purchase the Receivables from Seller and that all necessary proceedings on its part have been duly taken to authorize this purchase. c. It will comply with all applicable laws, rules) regulations. ordinances and judgments relating to or in any way affecting the purchase of the Receivables by Buyer) the ownership thereofby Buyer or the collection or enforcement thereof by Buyel'. d. Except as provided in paragraph 5 hereof, the relationship of the parties is that of seller and buyer and Buyer shall have no authority ~CF I."''' S&. Cap""".;.,.. -.: - ::~~~ . ~ \1 " l~:Sf.. ::.:~ .- .. :: , -.... ..>>ot'". .~~.:tf(;.':' ..-..1i..... "~~;" ,"",.. . ~~~:' " 0" " .il' J~l "~..'" ." ....,1.. ~::'..: ".:.. ..<fIt' .'):.'~'! ..2f~, . }~~~j .. .1;(, ,.!J;.. . ..........: ~. ~~' ..:....f~. :~....).I,. ;~~ (.t3-l~; ':i':'.' ' ,~ s~ '~t cffiflnanclal or capacity otherwise to bind or commit Seller to any act. obligation or liability, e. Buyer will indemnify.and hold Seller barmless from any'aod all claims, demands, actions, causes of actions, suits,! costs, fees and expenses arising from or in any Way connected with Bu)b:'s attcmpt(s) to collect on any Receivable or concerning the failure of'Buyer to keep or comply with any term. condition, representation. warranty or agreement contained herein or the incorrectness or falsity of any representation or warranty, which is or becomes WltruC in any material respect. f. SeUer will indemnify and hold Buyer harmless from any and all claims, demands, actions, causes of actions, suits, cost~ fees and expenses arising from or in any way connected with Seller's attempt(s) to <.:ollect on any Receivable or concerning the failure of ScHer to keep or comply with any term, condition. representation, wammty or agreement contained herein or the incorrectness or falsity of any representation or warranty, which is or becomes untrue in any material respect. ANY ADDENDUM OR EXHIBITS ATTACHED HBRB TO BECOME A PART OF AND ARE INCORPORATED INTO THIS AGREEMENT. N~P~~ By: · . S&~~ Date. _ '.JI.~JI' lissa Bauerlein Date: qf~/ ~F In;lI.b S&P Cllplrallnltiall .~; ~: . . w~ . -.;'.","J,,\ ~., ~?.,... t.. ..: ;. ~II. .,.,.;.. .'~''':;''. .H 'It. ;. ;. ~'$o'.''''' ..., . " a,-':-~(" ,. .. .:-- 'r~"'~ i Ii!o:' 'fo" ~:.~.. '~'io.. '-. 1.~~. ..~;ji"'~ . .. "',.\'00, ....... ...~I~ ~:b~ ".. . ~~. '~~'. .~...I.." '-. ,~, . . ,. . . . cffiflnanclal Exhibit A Sold Portfolio Description Buyer bas agreed to tuud the before mentioned price of for tbe AI,oa.tes Consumer PortfoUo. CitiFinancial will provide in this portfolio of ~':':': . accounts that total' in Dustanding. The purchase price has been agreed at L~ on each dollar. eller Melissa A. Bauerlein Supervisor CitiFinancja1~ Investment Recovery yP/' Date ~lnlti'I' s&.P Capital Initials 2do~ .' ~ S & P CAPITAL INVESTMENTS, INC. SALE AGREEMENT TH~: AGREEMENT, with the effective date of March 18,2004, is made and entered into by and between S & P Capital Ime.!tments Inc., (hereinafter called "S &. P"), a Texas Corporation, located at 1601 W. Airport Freeway, Euless, TX 76(14) and LHR. Inc. (hereinafter called "LHR''), a New York corporation, located at 56 Main Street, Hamburg, New York 14( 7 S. S &. P has purchased a portfolio of charged-off consumer loan accounts from CitifinanciaJ Corporation (hereinafter call:41 "Citifmaneial"), and LHR. Inc., bas purchased a portion of these accounts from S &. P under the following terms; L On March 18, 2004, S & P purchased a portfolio of charged-oft' consumer loan accounts from Citifinancial. This p~, and the interaction between S &. P and CirifinanciaJ is governed by the "Purchase and Sale Agreement" by and between Citifmancial and S &. P dated March 18, 2004 (hereinafter called the "Citifinanciall S &. P Agreement") 1 version of which is attached hereto as Exhibit A. 2. )n March 18, 2004, S &. P sold a portion of the portfolio of charged-off consumer loan accounts that it had lW'chased from Citifinancial to LHR Inc. The accounts sold by S & P to LHR Inc. are as described in Schedule I, ; LttaChed hereto as Exhibit B. A Bill of Sale regarding these accounts is attached hereto as Exhibit C. 3. ~; &. P provides no representation or warranty ofcollectability, or any other warranty regarding the accounts. 4. I.HR Inc agrees that its purchase of Citifinancial charged..off consumer 10m accounts from S &. P is governed by the ,ame conditions set forth in the "CitifinanciaJ IS&. P Agreement" attached hereto as Exhibit A and incorporllted . .erein by reference. This includes, but is not limited to, the availability and access to documents supporting the ,arious accounts as outlined in Paragraph 5.5 of tile" Citifinancial IS&. P agreement" 5. . 'his agreement, including the Exhibits hereto, eontain all ofthc terms, conditions and representations and warranties I greed upon by the parties relating to the subject matter of sale of accounts which occurred on March 18, 2004. and S lpcrsede all prior agreements, negotiations, comspondence, undertakings and communications of the parties, oral or ,ritten, respecting this subject matter. This Agreement shall not be amended or modified except by a writing duly e <ecuted by 5 &. P and LHR. 6. 1'- othing in this Agreement shall confer any rights upon any person who is not a party to this Agreement. 7. T!tis Agreement may be signed in any number of counterparts with the same effect as if the signatures to each Cllunterpart were upon a single instrument, and all such counterparts together shall be deemed an original of this A veement 8. T lis Agreement shall be governed by and construed in accordance with the laws of the State of Texas, without regard fo . the principles of conflict of laws. In the event of any action arising out of this Agreement, the prevailing party sb ill be entitled to recover its reasonable costs, expenses and attorney's fees incurred in connection with the dispute fr, m the other party. 9. NIl thing in this Agreement is intended by either party to create, offer, buy, sell, or solicit the sale ofa security. s c ~ P Capital Investments IDe:. By'~~~~~ Nell F atel- Presldellt LHR, Inc. a New York CorporatioD By: SCHEDULE 1 11. e Citifinancial consumer Joan accounts sold by S & P to LHR, Inc. on March 18, 2004, includes accounts representing an total amount of outstanding debt of at the time Ci\ ii inancial charged the debts off its books. These accounts were transferred from S & P to LHR as ent ri es on a spreadsheet. BILL OF SALE On J v1arch 18, 2004, S & P, for valuable consideration, transferred to LHR Inc., its successors and assigns, all right title and interest to a group of consumer loan accounts originally initiated by Ciiliinancial, and previously charged off the books of Citifmancial, without representation or warnnty of C(lllectability or otherwise, except as stated in a Sale Agreement effecting the transfer. These aceD unts represent a total amount of outstanding debt of $ at the time Citifinancial char~ed the debts offits books. These accounts were transferred from S & P, to LHR Inc. as entrie:: on a SpI eadsheet. Effe. ~ve: March 18, 2004 S & P Capital Investments Inc. A TExaS Corporation BY:_~& l' . Patel- i' President LHR, INC 56 MAIN STREET HAMBURG, NY 14075 888-275-8116 DEBTORS NAME: JASON M. BOLAN DEBTORS ADDRESS: 111 S. PRINCE ST, APT 5C OTY & STATE: SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT ACCOUNT NUMBER: 536360 ORIGINAL CREDITOR: OllANANOAL ORIGINAL ACCOUNT NUMBER: 09080356011 CURRENT STATEMENT DATE: MAY 23, 2005 PLACEMENT BALANCE: $6,199.18 PRINOPAL: $6,199.18 DATE OF LAST PAYMENT: MAY 31, 2002 INTEREST: $1,451.43 TOTAL AMOUNT OF PAYMENTS MADE TO LHR: $0.00 TOTAL AMOUNT DUE: $7,650.61 THIS COMMUNICATION IS FROM A DEBT COLLECTOR AND IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SCRIBED AND SWORN TO before me, a Notary Public, in and for Erie County and State of New York, this ~ day of May, 2005. ~~ My Commission Expires: ~ JENNIFER A. HURLEY Notary Public, State of New York No. 02HU6091 064 Qualified in Erie County Commission Expires April 21, 2007 ,1>\ b. ... -. T ~ ". T"'""~ P. }+' }l"W -'os. '! l' i . I: ~~ne LetDI',') LH~ I'me .T _ Pb;71tiif T" .... J' .. .. .. J.'" ...' ... .,. .J,.. 't,.. .. f""1' 1" i.le-~:n: 7~ry T;n.,(j.l;; ~ne ~LP:T!e~.s Q1 ::a~ COnI;.c1.n!e~ ~n. une '::OTegDmg_ \....;cmplamt a.i:~ trle a.n.d c:::~~t.. I und~~an.d that f71.1se st..a.ten:ents he...~ are made S~~;":""--"'""~ ;.:;:,.,.~""...,-h..':~ ""'I~1.q p- L:..........: l..:..._'-' .,'" ~_ ':'--"i..a.,...;. u.:l.~ <.....i -=-_ __ :,;... c..s_ S49C4. rela.tm~ :.0 unsworn f;;1:rL.~~ticn. \.1 ~ . _ ~') a.:rthorities.. ~ \M(n) Ji' J-/a~~ A.. ffia':2t ...__fk?;deot ENNIF R A HURLEY ."- arv publiC., StClte of New Yorl< No. 02HU6091 064 Qualitied in Erie County 07 '. . n EXPires .A.pn\ 21,20 ComrtlISSIO" . . TEile ,5b maIn \5tee+~ A..dti-e..~ 4075" ) o~~z.<1 5~~~bO , of <<t. (J if'{ Q /J l- V\ r-' n (-::::J <-, ~ trt \,:, Cjl <0 IYJ C1 ~ "_,I - f"',,') , ~ O~ -C r -:J \) if< -",'" _:~". ....0 E (-:? CY (.., en --L.... - /-\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA LHR, INC., assignee ofCITIFINANCIAL NO. 2005-5039 IN CIVIL ACTION Plaintiff(s) -vs- JASON M BOLAN Defendant(s) PRAECIPE TO REINSTATE COMPLAINT CODE- FILED ON BEHALF OF PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: James R. Apple, Esq. PA LD. No. 37942 Charles F. Bennett, Esq. PA LD. No. 3054l Joel E. Hausman, Esq. PA LD. No. 42096 APPLE AND APPLE, P.C. Firm No. 719 4650 Baum Boulevard Pittsburgh, PA l5213-1237 Telephone: 4l2-682-l466 Fax:4l2-682-3l38 :{ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA LHR, INC., assignee ofCITIFINANCIAL NO. 2005-5039 IN CIVIL ACTION Plain tiff( s) -vs- JASON M BOLAN Defendant(s) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY SIR: Kindly reinstate the Complaint in the above-captioned matter. APPLE AND APPLE, P.C. Dated: 11/;/~5' I ( BY:~ torney laintiff(s) o c ~~ ,::,.::> cJ\ - s~ C) r) ~\ -l ::c....,., i"'lr -om '".j\.....-' ~_:~() .-<-" ,-~ "'.-i\ "; ("~) ',.,..nl ,. ~:.:.:.\ -;:.. ;Q ?'::'" ..- 'f! co SHERIFF'S RETURN - REGULAR CASE NO; 2005-05039 P COMMONWEALTH OF PENNSYLVANIA; COUNTY OF CUMBERLAND LHR INC VS BOLAN JASON M WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BOLAN JASON M the DEFENDANT , at 1856:00 HOURS, on the 30th day of November, 2005 at 115 E ORANGE STREET SHIPPENSBURG, PA 17257 by handin9 to JASON M BOLAN a true and attested copy of COMPLAINT & NOTICE t0gether with and at the same time directin9 His attention to the contents thereof. Sheriff's Costs: Docketin9 Service Affidavit Surcharge So Answers; 18.00 19.20 .00 10.00 .00 47.20 r' ,") /" .t/ # . ;tf;:>~<,.,:;.":~",..<;~,';~f~' "4~,,. ~:&-::d ...-. ~"{ ..- , R. Thomas Kline 12/01/2005 APPLE AND APPLE Sworn and Subscribed to before me this '1:- By; ~L::v/ -" , Deputy Sheriff day of i~< ;l 00 of A.D. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA LHR, INC., assignee ofCITIFINANCIAL NO. 2005-5039 IN CIVIL ACTION Plaintiff(s) -vs- JASON M BOLAN Defendant( s) PRAECIPE FOR DEFAULT JUDGMENT CODE- FILED ON BEHALF OF PLAINTFF COUNSEL OF RECORD FOR THIS PARTY; James R. Apple, Esq PA I.D. No 37942 Charles F. Bennett, Esq. PA I.D. No 3054l Joel E. Hausman, Esq. PA I.D. No 42096 Apple and Apple, P.C. Firm No. 719 4650 Baum Boulevard Pittsburgh, PA l5213-1237 Telephone (4l2) 682-l466 -. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA LHR, INC., assignee ofCITIFINANCIAL NO. 2005-5039 IN CIVIL ACTION Plaintiff(s) -vs- JASON M BOLAN Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the above- named Defendant(s) in Default of an Answer, in the amount of$7,959.98, computed as follows: Amount named in Complaint $7,650.61 Interest from May 24, 2005 to January 25, 2006 on $7,650.61 $309.37 Less payment of: -$ $ Attorney fees TOTAL $7,959.98 I certify that Notice of the intention to enter this Judgment was given pursuant to Pa. R.C.P. 237.1. A copy of said Notice is attached, and was mailed on January 20,2006 by regular mail, postage prepaid and, addressed as follows: Defendant: Jason Bolan I 15 E. Orange St. Shippensburg P A 17257 APPLE AND APPLE, P.c. Dated: ~<</46 By: . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA LHR, INC., assignee of CITIFINANCIAL NO. 2005-5039 IN CIVIL ACTION Plaintiff(s) -vs- JASON M BOLAN Defendant(s) Jason M Bolan 115 E. Orange St. Shippenshurg, P A 17257 Date of Notice: Januarv 20.2006 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 DAYS FROM THE DATE OF THIS NOTICE. A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 1800-990-9108 ~ . " By: (. James R. Apple, Esq. Attorneys for Plaintiff(s) 4650 Baum Boulevard Pittsburgh, PA 15213-1237 Telephone (412) 682-1466 ~,> c.:_.~ C ~ 0 N ~ Cl~' -c, ~ ;C l-':-' 1- \:\: c:: () , 0-" ~ -- ...() CY ~ fd .!::: .J:::. c..) ~ I)- tn r0 QJ ..l: -() 0 ~ . ~ f: ::e ---t:" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA LHR, INC., assignee ofCITIFINANCIAL NO. 2005-5039 IN CIVIL ACTION Plaintiff(s) -vs- JASON M BOLAN Defendant(s) NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (X) Defendant () Garnishee You are hereby notified that the following Order or Judgment was entered against you on }:-pJ) ~ ;).tVJb . I (X) Assumpsit Judgment in the amount of$7,959.98, plus costs. ( ) Trespass Judgment in the amount of $ ( ) Ifnot satisfied within sixty (60) days, your motor vehicle operator's license and/or ( ) Registration will be suspended by the Dept. of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (X) Entry of Judgment ( ) Court Order ( ) Non-Pros ( ) Confession (X) Default ( ) Verdict ( ) Arbitration Award ( ) Other Jason M Bolan 115 E. Orange St. Shippensburg, P A l7257 a . 0 ..~'/ OTHoi(~ By: Prothonotary (or Deputy)