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HomeMy WebLinkAbout05-6019MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominezyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 CUMBERLAND COUNTY COURT OF COMMON PLEAS FAIRLANE CREDIT P.O. Box 6508 Mesa, Az 85216-6508 V. BRIAN EVANS 10 East Locus Street Inolasburg, Pa 17025 Plaintiff, Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff Case No. U ?) b o /fj CU4"tt CIVIL ACTION COMPLAINT NOTICE You have been sued in court . If you wish to defend against the claims set forth in the following pages, Von must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and tiling 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 ajudgment may be entered against you by the court without further notice for any money claimed in the complaint Or for any other claim or reliefrequested by the plaintilE You may lose money or properly or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SEr FORTH BELOW to FIND OU'I WHERE YOU CAN GET LEGAL HELP. AVISO To han demandado a usted en la carte. Si usted quiere defenderse de estas demandas expuestas en has paginas siguientes, usted lien veinte (20) dias de plazo al partir de la Fecha de la den anda y la notifie.eion. Hate falta asentar una cmnparcocia estrus o eat persona o can on abogado y entregar a la torte to forma esenta sus defensas o sus objeciones a has demandas on contra de sat persona. Sea avisado que si usted no se defiende, la torte lomars medidas y puede Continuator la demanda on contra says sin previo aviso o notification. Ademas, la corte puede decidir a favor del dentandante v mquiere que usled cunrpla con todas las provisions do esta thereinto. Usted puede ponder dinero o sus propiedades u otros derechos importanfes pars used. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIAI'AMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAT SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUF.DE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 ARBITRATION 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 Attorneys for Plaintiff (Z I--)) 7259-JLJ1 FAIRLANE CREDIT P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. BRIAN EVANS 10 East Locus Street Inolasburg, Pa 17025 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. CIVIL ACTION COMPLAINT 1. Plaintiff, Fairlane Credit, is a Corporation with its principal place of business at P.O. Box 6508, Mesa, State of Arizona. 2. Defendant, Brian Evans, is an individual who resides at 10 East Locus Street Inolasburg, Pa 17025. 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 December 7, 2001, 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 $15,265.00, at an annual percentage rate of 14.840%, in order to purchase a certain motor vehicle, a 2000 Pontiac Grand Am, 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 $364.10 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 payments until 11/17/03, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 7. By reason of the default, the Defendant(s) is indebted to Plaintiff for the balance of $ 11613.59. 8. In addition to the foregoing, there is due from the Defendant(s) interest in the amount of $3289.98. 9. The total amount due and owing is $14903.57. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $14903.57 as well as additional interest that may accrue and such other and further relief as this Court may deem equitable and just. Res u_llysubmitted, A 1 DLEMAN, P.C. i THOMAS R. D INCZYK, ESQUIRE Attorney for Plaintiff VERIFICATION I, THOMAS R. DOMINCZYK, ESQUIRE, verify that lam the Attorney of record for Plaintiff, FAIRLANE CREDIT, 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 unsworn falsification to authorities. B7 THOMAS R. DOMINCZYK,ESQUIRE DATED: MOM FA "LC Rw. 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"'hi. wab.mmwn mop r ere we HOLDER OF THIS CONSUMER CREDIT SELLER OF GOODS OR SERVICES OBTAINED VMH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DERORHEREUNDRR. Y.. bete, vatted te,verentu We data. 76Wt meRW) below )a do. if the Eorrewer demT pe, the debt, ye. will have te. Be we yera m e0erd he Pee EY. beVe to, mad net Yw Weam ettepl Nb rapouibHry. Y. mm) lure to P., rap 1. Nee h0 emommt a me deM E me Brve. doa moe q). Y. ., ebo beee Ira M bb let or Np Th. 4en4e t II,Nemml. T aD meMed an'ta v. e obact ed We debt can ft. be I. wttbovt Ott, to eslleet from the Baccarevow. it if " The Leeds tde al the rams bas epM )vo OH m be hrr epWt the e Recreative, each u oft m at. thN debl to met In ddevl4 that fact .7 become • pert olEer eaWtrecad. pp'S4t S/ ?. 1w n]-_j / (\ CA (i l) T? rJ lL SHERIFF'S RETURN - REGULAR CASE NO: 2005-06019 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FAIRLANE CREDIT VS EVANS BRIAN 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 BRIAN the DEFENDANT , at 1959:00 HOURS, on the 28th day of November , 2005 at 10 EAST LOCUST STREET ENOLA, PA 17025 EVANS by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 15.36 Affidavit .00 Surcharge 10.00 .00 43.36 Sworn and Subscribed to before me this (. day of RXZC?r o7 "7 -"? A . D . c rot on tary So Answers: 7 i R. Thomas Kline 11/29/2005 MAURICE & NEEDLEMAN By: cy- Deputy 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 FAIRLANE CREDIT Plaintiff V. Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-6019 BRIAN EVANS Defendant(s). PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the verification of the Plaintiff, Fairlane Credit, for that of the verification previously filed. Respectfully submitted, MAURICE & NEEDLEMAN, P.C. TMOMAS R Attorney for ESQ Date:( ?r- f4 CERTIFICATE OF SERVICE 1, THOMAS R 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 Fairtane Credit, to be served by regular, first class mail, postage pre-paid upon: BRIAN EVANS 10 East Locus Street Inolasburg, Pa 17025 Respectfully Submitted, MAU JJE & NEEDLEMAN, P.C. BY: THOMAS RROMINCZYK, ESQ Attorney for Plaintiff DATED: //T/d? VERIFICATION r?itrverify that I am the Authorized Representative for Plaintiff, Fairlane Credit, 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 ?? DATE: k?'- c BRIAN EVANS Our file no. 2191 48047000000036387692 ?, ?> -? .. ` ?. 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 FAIRLANE CREDIT Plaintiff V. BRIAN EVANS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-6019 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, BRIAN EVANS in the amount as follows: Principal Amount $ 11613.59 Interest to Date $ 3733.83 Costs $ 98.86 Attorneys Fees $ 0.00 TOTAL $ 15574.24 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 FAIRLANE CREDIT Plaintiff V. BRIAN EVANS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-6019 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 01/05/2006 to Defendant, BRIAN EVANS , 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 01/05/2006, a copy of the receipt for certified mailing to the Defendant and affidavits of service of said notice are all attached hereto. MAI BY: ESQ. Attorney for Plaintiff ...? MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Pem1 Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff tziol iay-,ui FAIRLANE CRJ Plaintiff v. BRIAN EVANS CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-6019 IMPORTANT NOTICE, TO: BRIAN EVANS DATE: January 5, 2006 10 EAST LOCUS STREET INOLASBURG, PA 17025 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 DLEMAN, P.C. BY 7HO%MAA DOMI NCZYK, , ESQ Attorney for Plaintiff rFRT/F/F') ,*r?.'.f-! DONALD MAURICE 250 STATE ROUTE 28 STE 203 BRIDGEWATER, NJ 08807 A. HI/q(%? tors: ?Add a?. a.Oq sent) B. Reclead By: (Pattie Prin C!nM) Ma r)-024? G. D.[e o 77 D. Addressee'. Add...I won miFmmem.m and e,3sres) Secondary Address I Suds I Ad. I Floor (Pamirs Print Cattily) Delivery Address City State ZIP+d Coda .° IIIIII'IIII?IIIIIII?I?IIIII?IIINI?I?,. ?Fi nII111N1IINiIVllllll?l?llllll 7155 5474 41M 3617 9941 RETURN RECEIPT REQUESTED ArdaM Addressed To: It1111111111rrrIJJrLIt,IrLl 3RIAN EVANS 10 EAST LOCUS STREET 7-nola PA 17025 r Suite 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. Maurice Member NJ Bar Board Certified Creditors' Rights Law American Board of Certification Joann Needleman Member PA & NJ Bar Thomas R. Dominczyk Member NJ & PA Bar January 5, 2006 VIA CERTIFIED BRIAN EVANS 10 EAST LOCUS STREET INOLASBURG, PA 17025 ARTICLE NUMBER 7155 5474 4100 3617 6941 ARTICLE ADDRESS TO: BRIAN EVANS 10 EAST LOCUS STREET Enola PA 17025 FEES Po to a per iece $0.37 Certified Fee 2.30 Return Receipt Fee 1.75 Total Postage & Fees: 54.42 Postmark Here RE: FAIRLANE CREDIT v. BRIAN EVAN'S CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 05-6019 Dear BRIAN EVANS: 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 11/28/2005 . 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. ry truly yours, TH AAS INCZYK, ESQ. New Jersey Office MAURICE & NEEDLEMAN, P.C. 250 Route 28 West Suite 203 Bridgewater, NJ 08807 tel. 908.575.0220 fax 908.575.0632 Enc THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR 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 FAIRLANE CREDIT Plaintiff V. BRIAN EVANS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-6019 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: BRIAN EVANS, 10 EAST LOCUS STREET, INOLASBURG, PA 17025 NEEDLEMAN, P.C. BY: 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 FAIRLANE CREDIT Plaintiff V. BRIAN EVANS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-6019 AFFIDAVIT OF MAIL SERVICE STATE OF NEW JERSEY SS. COUNTY OF SOMERSET THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law, deposes and says that she is an attorney at law and that on 01/05/2006(date) he/she mailed a written Notice of Intention to File the Praecipe to Defendant, BRIAN EVANS , atl0 EAST LOCUS STREET, INOLASBURG, PA 17025 by certified mail, article nos. 7155 5474 4100 3617 8941. 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. MA BY: ESQ. SWORN TO AND UBSCRIBED before me this•23' ay of Ji 011 (. 200V N tar 'P 1SE? Y L 4? ERA A NOTARY PUBLIC OF NEW JERSEY ,4v Commission 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 FAIRLANE CREDIT Plaintiff V. BRIAN EVANS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-6019 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY SS. COUNTY OF SOMERSET 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, BRIAN EVANS , 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. MAURjeE-3kkNEEDLEMAN,-P.C. ESQ. Attorney SWORN TO AND SUBSCRIBED before me this<; 3day of, / ,i 200 (1. otar d P4/ RA A NOTARY PUBI.[C OF NEW JERSE') My Commission Expires 11/01/2009 n -aa -o -c ` vy'? ZD .: ' 7 t ? L? 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 FAIRLANE CREDIT Plaintiff V. BRIAN EVANS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 05-6019 O Notice is hereby given that a judgment in the above-captioned matter h?as been entered against you in the amount of $15574.24 on L(.? l Z(jp(o O A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. rothonot C erk by: 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) Attorneys for Plaintiff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FAIRLANE CREDIT Plaintiff, V. BRIAN EVANS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-6019 CERTIFICATE PREREQUISITE TO SERVICE OF SUPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Plaintiff, FAIRLANE CREDIT, certifies that: (1) a notice of intent to serve subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at lease (20) twenty days prop rot the date on which the subpoena is sought to be served; (2) a copy of the notice of 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 subpoena. JJJoN s q. Date: January 22, 2007 Y A Attorneys at law Suite 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. Maurice Member NJ Bar Board Certified Creditors' Rights Law American Board of Certification Joann Needleman Member PA & NJ Bar Thomas R. Domincxyk Member NJ, NY & PA Bar New Jersey Office MAURICE &NEEDLEMAN, P.( . 150 Route 28 West Suite 203 Bridgewater, NJ 08807 tel. 908.575.0220 fox 908.575.0632 January 22, 2007 BRIAN EVANS 10 EAST LOCUS STREET INOLASBURG, PA 17025 RE: FAIRLANE CREDIT v. BRIAN EVANS CUMBERLAND COUNTY COURT OF COMMON PLEAS 05 -6019 Dear Mr. Evans: Enclosed please find Notice pursuant to Pa.R.C.P. §4009.24 advising you of Plaintiffs intention to serve subpoena upon Citifinancial. A copy of the subpoena is attached and which will have the Prothonotary's seal upon service to Citifinancial Thank you for your attention to this matter. Very Truly Yours, RICE & EEDLEMAN, P.C. J eed man, Esq. the Firm JN/ce Enc. MAURICE & NEEDLEMAN, P.C. By: Joann Needleman, Esq. Identification No. 74276 Suite 935, One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7161 Attorney for Plaintiff FAIRLANE CREDIT Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-6019 BRIAN EVANS Defendant(s). NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff, FAIRLANE CREDIT, by and through its attorney, Joann Needleman, Esq., intends 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, MAURICE & NEEDLEMAN, P.C. i JOANN N ; DLEMAN, ESQ % , . , V ? c GLn bentk(A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GYsCCY?.? VC el-S n File No. V J G o t q WV6 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: -746 P& C.-,Qxn a ? . (Name of Person or E&ty) i Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: m? "1 0 7 T\ evGKs Arc # 6©7 -2, 97 cash a Gree t ar Lv a It at ?C?1dvtCe N [Vr ? 92,S I?JVI Pen n (.Qr?t?, p?Nrt?/IP4 t 09 (Address) tq/o 3 You may deliver or mail legible copies of the documents or produce 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 compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: (9 C.t r? Y1 AD 1?SS• l? e TELEPHONE: ' 2-((:; SUPREME COURT ID # ATTORNEY FOR: I?tCJtL1- ?QY?r1?S X10 ? c o c R-- BY 2 THE URT: Date:,I)gc T- )O(oj 'Seal of the Court thonotary iv' n Deputy r-? a_. z-n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Fairlane Credit ( ) Confessed Judgment ( ) Other File No. 05-6019 Atty's Comm BRIAN EVANS Costs to E Ocus4 - ,,csl?tO? l7S-3D TO fHE PRTHONOTARY?OF THE Sall D 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 a writ of execution in the above matter to the Sheriff of Cumberland for debt, interest and costs, upon the following described property of the defendant(s) County, NEW CUMBERLAND FCU 345 LEWISBURY Rd, New Cumberland, PA PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff ofcumberiand 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) -any and all accounts and property in the name of the above Defendant SS# 199-66-6769 and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). O (indicate) Index this writ against the gamishee(s) as a lis pendens defendant(s) described in the attached exhibit. / Date Signature: Print Name- Address: real estate of the Philadelphia, PA Attorney for: Telephone: 215 789 7154 Supreme Court ID No.: vs. Amount Due 15574.24 4 Interest 3/1/06 $1671.78 Plaintiff (over) 935 One Penn Center C44 io& _n O V v o flA -64. ..? 71 rJ 0OQW 00 6. o t C rn n } ?°' y cn 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6019 Civil CIVIL ACTION'- LAW TO THE SHERIFF OF YORK COUNTY: To satisfy the debt, interest and costs due FAIRLANE CREDIT, Plaintiff (s) From BRIAN EVANS, 10 E. Locust Street, Enola, PA 17025-3024 (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 GARNISHEE(S) as follows: NEW CUMBERLAND FCU, 345 Lewisbury Road, New Cumberland, PA 17070 any and all accounts and property in the name of the above defendant. 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 $15,574.24 L.L. $.50 Interest 3/1/06 -- $1671.78 Atty's Comm % Atty Paid $150.86 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 12/27/07 (Seal) REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: MAURICE & NEEDLEMAN, P.C. 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 C s R. Long, Prothonotary By: &6a At AL Deputy Supreme Court ID No. 74276 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 BY : Charlene Taylor Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (215) 789--/I-)l FAIRLANE CREDIT Plaintiff, V. BRIAN EVANS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 05-6019 PRAECIPE TO DISSOLVE/WITHDRAW GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve/withdraw garnishment upon New Cumberland FCU forthwith. Date: January 18, 2008 09 O ! "7 v n W 00 clJovoy EXP 3/26/08 COUNTY OF YORK SERVICE CALL. OFFICE OF THE SHERIFF (717) 771-9601 45 N. GEORGE ST., YORK, PA 17401 11"rtif 1/17/08 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1 THRU 22 DO NOT DETACH ANY COPIES 1 PLAINTIFF/S/ (c, N ^ 2 C - JG 4 TYPE OF WRIT OR COMPLAIN -1 3 DEFENDANT/S/ IN SERVE AT 'y"tGt f^ CUC2 nS10 E LOCUST ST ENOLA PA 17025 Q64 C, nts? 04 n (j RATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO E l VIED ATTACHED, OR SOLD 5 NAME OF INDIVIDUAL, OMPANY, CORM416ej,[Cjh GARNISHEEO? MEMORY LANE w c4 G? 6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT N9, CITY. BO€t0, TWP STATE AND ZIP CODE) YORK PA 1?402 ri f ?n 7 INDICATE SERVICE O PERSONAL U PERSON IN CHARGY V DEPUTIZE U CERT MAIL U 1 ST CLASS MAIL U POSTED U OTHER NOW 20 I, SHERIFF OF YORK COUNTY, PA, do hereby deputize the sheriff of COUNTY to execute this Writ and make return thereof-according to law. This deputization being made at the request and risk of the plaintiff., SHERIFF OF YORK COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE V SERVE GARNISHEE NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATC N - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, afte lying pe of levy or attachment, without liatality, on the part of such deputy or the sheriff to any plaintiff herein tar any loss, destruction, or removal of any property before she 7s le thereof 9. TYPE f?'-'- -? and ADDR SS of A ?Rr NEY/ ORIGINATOR an IG 7E1 12- 12. . rTEP? rJ?? ? IER 11.1 DATE FILED SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESSt%ELOW: (This area must be completed d notice is to be mailed) ,t 13. 1 acknowledge receipt of the writ 23. Advance Costs 24 Service Costs 25 N/F 26 Mileage r9.31 7. Postage 28. Sub Total 29. Pound 30 Notary 31 Surchg. 32 Tot. Costs 33 Q[¢liNo 15 0 . ATY 46.00 5.05 60.36 5.00 30.00 95.36 $54.64 26528 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37 Notary Cert. 38. Mileyf/"ge/Not Found 39. Total Costs 40 Costs Due or Refund 41. AFFIRME and 1Wbscn o bet a me thi a? 44. SO ANSWERS OVA, 42, day of M2,43 De ` l? 451 / r C7 NOTARIAL SEAL 46. Signature of York 47. DATE LISA L. BOWMAN NOT ARY PUBLIC County Sheriff 4/3/08 CITY OF YOF';, "ORK COUNTY MYCOMM;SS:GN ';i `Si'UG.12,2009 48 Signature or Foreign 49 DATE 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - ShenRs Office 9r complaint as indicated above. LT HO R P E I 1/11/07 I 3'/26/08 16.- HOW SERVED: PERSONAL ( ) RESIDENCE ( ) POSTED( ) POEX SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. O I hereby certiy and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 18. NANQ AND TWLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOVIN ARr)VF IRwtari,v,ehin en 17--f- -0 , o n?•e r ce .: a ?n r.. e • ce ,. ¦ CanpW UM 1. 2.04 3. Afto CMVkft A. D AGeM ? y, CO) ¦ Print your mmrle and ofte a can the warn ^?--?--- O Ad*onW ., ` so hash we can Mum the owd to you. BRpslved by 0 Dslwery ? - ty j ¦ Attach this and to the b#A* of the m0piecle, or on the front B space perffitte Ain &,a K"3" G r 'C 4 D. Is d*.wy addan *W item 1? 13 YS8 y 1. Artfak Addressed to: BRIAN EVANS If YM enisr'd*my address below .4 No 10 EAST LOCUST ST m ENOLA PA 17025 Moo 01 Palum RecW for Merchandise ? Insured Mail 0 O.O.D. 4 0300 Fee) (Tr xferfromswvkoiliW 7005 2570 0002 1292 1188 PS Form 3811, February 2004 Donmmic Ratum FMoeV 7M-95-02-M-'1540 U.S w CERTIFIED MAIL- REC p. WOEA?N E 0 U a Postage $ ? Certified Fee 2.65 Postmark 0 Retum Receipt Fee Hera (Endorsement Required} 2.15 O Restricted Delivery Fee / • 10 4 r%- (Endorsement Requi red) Lr'i rU Total Postage & Fees $ Ln a Sent ro a BRIAN_..EVANS------ ----------------- ------------- . .. "°,; 10 EAST LOCUST ST or PO Box No. s}aFe: ziP+d ?1VOZA pA ?CFZ"S SHERIFF' S RETURN OF SERVICE 01/15/2008 09:40 AM - SERVED TWO TRUE AND ATTESTED COPIES OF THE WITHIN WRIT OF EXECUTION AND INTERROGATORIES UPON ANN BERGDOLL, ASSISTANT MANAGER FOR NEW CUMBERLAND FEDERAL CREDIT UNION, THE WITHIN NAMED GARNISHEE, AT200 MEMORY LANE, YORK, PENNSYLVANIA, AND ATTACHED AS DIRECTED. 01/17/2008 SENT BY CERTIFIED MAIL, ONE TRUE AND ATTESTED COPY OF THE WITHIN WRIT OF EXECUTION AND CLAIM FOR EXEMPTION FORM TOBRIAN EVANS, THE WITHIN NAMED DEFENDANT, TO 10 EAST LOCUST STREET, ENOLA, PENNSYLVANIA 17025. 01/22/2008 RETURN RECEIPT FOR CERTIFIED MAIL TO BRIAN EVANS, DATED 1/18/08, ATTACHED HERETO. SHERIFF COST: $95.36 (PAID) SO ANSWERS, April 03, 2008 RICHARD P KEUERLEBER, SHERIFF WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 05-6019 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF YORK COUNTY: ??? To satisfy the debt, interest and costs due FAIRLANE CREDIT, Plaintiff (s) ?J From BRIAN EVANS, 10 E. Locust Street, Enola, PA 17025-3024 (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 GARNISHEE(S) as follows: NEW CUMBERLAND FCU, 345 Lewisbury Road, New Cumberland, PA 17070 any and all accounts and property in the name of the above defendant. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from` F paying any debt to or for the account of the defendant (s) and from delivering any property of the defendi it? (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 $15,574.24 Interest 3/1/06 -- $1671.78 Atty's Comm % Atty Paid $150.86 Plaintiff Paid Date: 12/27/07 (Seal) REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: MAURICE & NEEDLEMAN, P.C. 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 Supreme Court ID No. 74276 L.L. $.50 Due Prothy $2.00 Other Costs YORK CO SHERIFF COSTS $ lJ - P - Cn 0, idudis . Long, Prothonotary By: V_ . Deputy NVE COPY FROM REWORD In Togo" ~, t two unto set my hanc. end the sW of said Cart at CO*, ` Pa. TbL- ? -. 01 . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6019 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FAIRLANE CREDIT Plaintiff (s) From BRIAN EVANS, 305 BASIL CT, YORK, PA 17402 (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 GARNISHEE(S) as follows: M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 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 $15,389.24 Interest FROM MARCH 1, 2006 - $5,591.48 Atty's Comm % Atty Paid $185.36 Plaintiff Paid Date: 3/14/2012 (Seal) L.L.$.50 Due Prothy $2.25 Other Costs David D. Buell, Pro onotary Deputy REQUESTING PARTY: Name ANDREW SKLAR, ESQUIRE Address: SKLAR - MARKIND 102 BROWNING LANE, BUILDING B, SUITE 1 CHERRY HILL, NJ 08003 Attorney for: PLAINTIFF Telephone : 856-616-8710 Supreme Court ID No. 65332 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FAIRLANE CREDIT I C") r-a _ 1335 S. Clearview Avenue I No. 05-6019 c_: Mesa, AZ, 85209 I rnW _ . n-". I c 7 i Plaintiff(s) I r ? CIVIL ACTION ? - --ic I ? CZ mac-, ) ? V. I PRAECIPE FOR WRIT OF EXECil$FN N ?_ Z!5 (Money Judgment) 3> y BRIAN EVANS 305 BASIL CT YORK PA 17402 i Defendant(s) TO THE PROTHONATORY: (1) Issue writ of execution in the above matter, directed to the Sheriff of CUMBERLAND County, against BRIAN EVANS , defendant(s) (2) and against, M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013 garnishee. AMOUNT DUE INTEREST from: March 1, 2006 PLUS COSTS cvk* cop c 4 3.3? gF 55. s0 g.W 1k. op a` 50(114 - C4(> a ? a? Dated: arc 7, 2012 FILE NO.: 6 $15,389.24 $5,591.48 Andrew War, Esquire Attorney for Plaintiff ID #65332 Sklar - Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill, New Jersey 08003 (856) 616-8710 11\ 1I ?A D X p'V' ?.?.as D1.ca 60• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FAIRLANE CREDIT :No. 05-6019 1335 S. Clearview Avenue ; Mesa, AZ, 85209 Plaintiff(s) v. BRIAN EVANS 305 BASIL CT YORK PA 17402 Defendant(s) WRIT OF EXECUTION NOTICE THIS PAPER IS A WRIT OF EXECUTION. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD OR TAKEN TO PAY THE JUDGMENT. YOU MAY HAVE LEGAL RIGHTS TO PREVENT YOUR PROPERTY FROM BEING TAKEN. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY OF THESE RIGHTS. IF YOU WISH TO EXERCISE YOUR RIGHTS, YOU MUST ACT PROMPTLY. THE LAW PROVIDES THAT CERTAIN PROPERTY CANNOT BE TAKEN. SUCH PROPERTY IS SAID TO BE EXEMPT. THERE IS A DEBTOR'S EXEMPTION OF $300.00. THERE ARE OTHER EXEMPTIONS WHICH MAY BE APPLICABLE TO YOU. A SUMMARY OF THE MAJOR EXEMPTIONS ARE LISTED BELOW. YOU MAY HAVE OTHER EXEMPTIONS OR OTHER RIGHTS. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW i. $300.00 STATUTORY EXEMPTION 2. BIBLE, SCHOOL BOOKS, SEWING MACHINES, UNIFORMS, AND EQUIPMENT. 3. MOST WAGE AND UNEMPLOYMENT COMPENSATION 4. SOCIAL SECURITY BENEFITS 5. CERTAIN RETIREMENT FUNDS AND ACCOUNTS. 6. CERTAIN VETERAN AND ARMED FORCES BENEFITS. 7. CERTAIN INSURANCE PROCEEDS. 8. SUCH OTHER EXEMPTIONS AS MAY BE PROVIDED BY LAW IF YOU HAVE AN EXEMPTION, YOU SHOULD DO THE FOLLOWING PROMPTLY: (1) FILL OUT THE ATTACHED CLAIM FORM AND DEMAND FOR A PROMPT HEARING; (2) DELIVER THE FORM OR MAIL IT TO THE SHERIFF'S OFFICE OF AT THE ADDRESS NOTED. YOU SHOULD COME TO COURT READY TO EXPLAIN YOUR EXEMPTION. IF YOU DO NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR PROPERTY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD ST CARLISLE, PA 17013 717/249-3166 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy iJ- HE PR Z012 MAR 21 AM 9: 22 Richard W Stewart Solicitor Fairlane Credit LLC vs. Brian Evans OFFICE `. THE :- RIFF 'CUMBERLANDANIA COUNTY Case Number 2005-6019 SHERIFF'S RETURN OF SERVICE 03/19/2012 09:23 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 19, 2012 at 0923 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Brian Evans, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Katie Swartz, Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 20, 2012 to Brian Evans at 305 Basil Court, York, PA 17402. SO ANSWERS, March 20, 2012 R-ONINV RAND SON, SHERIFF W iam Cline, Deputy ;o) GounfpSulte Sheriff ie!r?a;?fl_ li*;. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FAIRLANE CREDIT Plaintiff vs. No. 05-6019 ra ;nom ? v?!? I>c-a :x. c- ;1 1 . - iw BRIAN EVANS CIVIL ACTION Defendant Aft?WW. 40 INTERROGATORIES IN ATTACHMENT TO: M & T BANK , Garnishee: 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 judgment against you. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to him (her/them) on any negotiable or other written instrument, or did he (she/they) claim that you owed him (her/them) any money or were liable `^ him (her/them) for any reason? ?o HA's ?v FpRAOSpEN?C 2. At the time you were served or at any subsequent time was there in your possc?_ OVA NAM+?l S control or in the joint possession, custody or control of yourself and one or more persu.. property of any nature owned solely or in part by the defendant? N 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 the defendant held or claimed any interest? , 1 v 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had any interest? VI) 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent M7 hat was the consideration thereof? 6. At any time after you were served did you pay, transfer or deliver any money or property tot he defendant(s) or to any person or place pursuant to his (her/their) direction or, otherwise discharge any claim of the defendant(s) against you? ?CJ 7. If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically a on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption, the amount of funds in each account, and the entity electronically depositing those funds on a recur" basis. NL?) 8. T' a are a bank or other financial institution, at the time you were served or at any subsequent 1ne d; ' the defendant have funds on deposit in an account in which the funds on deposit, not _,,g any otherwise exempt funds, did not exceed the amount of the general monetary mption under 41 Pa.C.S § 8123? If so, identify each account. How much is the value of an property in your nnCCescinn helnnaina to the defendant(s)? M &yT BAND HAS NO OPEN ACCOUN-T Date: March 7. 2012 FOR ABOVE NAMED _ / Andrew Sklar, squire (ID #65332) Lloyd S. Markind, Esquire (ID#52507) Sklar - Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill, NJ 08003 (856) 616-8710 Disclosure You are hereby advised, pursuant to the Fair Debt Collection Practices Act, that this firm is deemed to be a debt collector attempting to collect a debt and any information obtained will be used for that purpose. Melissa M. Peters MAR Is-,ZDQ M&T Bank Andrew Sklar, Esquire (ID#65332) SKLAR - MARKIND 102 BROWNING LANE, BLDG B, STE 1 CHERRY HILL, NJ 08003 (856) 616-8710 Attorney for Plaintiff(s) Our File Number: FT 110316 i. t, i.. 11'' -5 2: L UMBERLA D COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FAIRLANE CREDIT :No. 05-6019 Plaintiff TERM VS. CIVIL ACTION BRIAN EVANS Defendant PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the attachment as to garnishee, M&T Bank, in the above captioned action. Date: March 30, 2012 Andrew Sklar, Esquire Attorneys for Plaintiff 9.SOpd ? ??sas SHERIFF'S OFFICE OF CUMBERLAND COUNTY Anderson ,y S Smith nief Deputy' : f to Richard W Stewart Solicitor Fairlane Credit LLC vs. Brian Evans Case Number 2005-6019 SHERIFF'S RETURN OF SERVICE 03/19/2012 09:23 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 19, 2012 at 0923 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Brian Evans, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Katie Swartz, Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 20, 2012 to Brian Evans at 305 Basil Court, York, PA 17402. 10/19/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $88.38 SO ANSWERS, October 19, 2012 RON R ANDERSON, SHERIFF S-0 L-t &:-# -5 ? 1- 3 Lazo 3