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Home My WebLink About06-1153MEMBERS 1sT FEDERAL CREDIT UNION, formerly DAFCU PLAINTIFF Vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA /~ JEFFREY A. BREWBAKER DEFENDANT :CIVIL ACTION -LAW NOTICE TO DEFEND AND CLAIM RIGHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE AR;n: ATTEMPTIING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMA'T'ION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. YOU HAVE BEEN SUED IN COLrRT. if you wish to defend agz.inst 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 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 claims 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 HAVF A LAW YER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHF.2E YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (7I 7) 249-3166 OR (S00) 990-9108 MEMBERS 1sT FEDERAL CREDIT UNION, formerly DAFCU PLAINTIFF V s. JEFFREY A. BREWBAKER DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: CIVIL ACTION -LAW NOTICIA Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted time viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectiones a las demandas en contra suya. Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition de demanda. USTED PUEDE PERDER DINERO O OTROS DERECHOSIMPORTANTESPARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 or I-800-990-9108 Kazl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 FEDERAL CREDIT UNION, formerly DAFCU PLAINTIFF V s. JEFFREY A. BREWBAKER DEFENDANT. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA Cep ~ ems--' CIVIL ACTION-LAW COMPLAINT AND NOW, comes Members 1 ~` Federal Credit Union, formerly DAFCU, the Plaintiff in the above captioned matter, by and through its attorney, Karl M. Ledebohm and makes the following complaint: Plaintiff, Members 1 s` Federal Credit Union ,formerly DAFCU("Members 1 S`") is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 1 2. Jeffrey A. Brewbaker ("Defendant") is an adult individuals having a last known address of 920 Wentzville Road, Enola, PA 17025. 3. On or about September 11, 1993 Defendant executed aPre-Approved Acceptance Certificate (the "Certificate") for a Visa Credit Card issued by Plaintiff. A copy of the Certificate is attached hereto as Exhibit "A" and made part hereof. 4. Plaintiff accepted Defendant's Certificate and sent to Defendant a Visa Credit Cazd, account #4287-5900-0036-1283 (the "Visa Account") and a Visa Credit Card Agreement and Disclosure Statement. 5. The Visa Account is governed by the Visa Credit Card Agreement and Disclosure Statement (the "Credit Cazd Agreement and Disclosure"}, a copy of which is attached hereto as Exhibit "B" and made part hereof. 6. Pursuant to the terms and conditions of the Credit Card Agreement and Disclosure, Defendant agreed to pay to Plaintiff monthly installments in an amount of not less than two percent (2.0°l0) of the outstanding balance on the account or $20.00, whichever is greater. 7. Defendant is in default of Defendant's obligations under the Credit Card Agreement and Disclosure and the corresponding Visa Account as a result of Defendant's failure to make the payments due to Plaintiff as set forth in the Credit Card Agreement and Disclosure, the last payment having been received by Members ls` on or about June 24, 2005. 8. By letter dated January 17, 2006, addressed to Defendant, Plaintiff demanded the payment of all amounts due under the Credit Card Agreement and Disclosure and the corresponding Visa Account. A copy of Plaintiff's Demand is attached hereto as Exhibit "C" and made part hereof. 9. As of the date hereof, Defendant is indebted to Plaintiff in the amount of TWELVE THOUSAND ONE HUNDRED TWO AND 44/100 ($12,102.44) itemized as follows: a. Principal $10,105.80 b. Unpaid finance chazge 566.64 c. N/A fees 30.00 d. Legal Fees* 1,400.00 e. Total due to Member 1 s` as of 2/21 /2006 $12,102.44 *Legal fees aze estimated in accordance with the terms and conditions set forth in the Credit Card Agreement and Disclosure. 10. Defendant also agreed under the terms and conditions of the Credit Cazd Agreement and Disclosure that in the event of default there under Defendant would pay, in addition to the amounts set forth in pazagraph 9 above, reasonable legal fees and costs incurred by Plaintiff as a result of the institution and prosecution of these legal proceedings. 1 L Legal fees and costs continue to accrue on the above obligation at the rate set forth in the Credit Cazd Agreement and Disclosure through the date of payment and including on and after entry of judgment on this complaint. 11. As set forth above, Plaintiff has made demand upon Defendant to make payment of all amounts due to Plaintiff under the Visa Account and corresponding Credit Cazd Agreement and Disclosure and, as of the date hereof, Defendant has failed and refused to make payment of all such amounts due to Plaintiff. WHEREFORE, Plaintiff, Members ls~ Federal Credit Union demands judgment against Defendant, Jeffrey A. Brewbaker, in the amount of TWELVE THOUSAND ONE HUNDRED TWO AND 44/100 ($12,102.44) together with additional attorney's fees and costs of suit and interest at the legal rate on and after the entry of judgment on this complaint. Respectfully submitted, Date: 'Z~2~i-O ~ Kazl I~1. Ledebohm, Esq. Supreme Court ID # :59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff t e..rr ~'`, S, ^ ~. ~.+' -.'-~'r'.rYO11M ~ewN n?~r a. 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N 4 y yy µ~~ t W *Yf~ nnA 'S' L tIx ~ ~.a.Y EXHIBIT "A" JflN-1(-zUUb Ufi,46 AM M~M~~I{S 1S 4' CULL~C'f1UNS (ltlybb'LU( Y,U4lU1 YISA Credlt Card Agreement and Dlscla:ure NMIA': SeE xaxxaid la impanenl lmarMbn aPYNap PaB IIpNNbAWdl dNirq anro, 1. MgIIMtlMW0al. the mllannN•am Ma lamllolYnp mxlaga in lAle a(Pawnil prtl In pD langMY hilNw sabnd%fnl hnrx/b.: (al 'WroM+'N'nMbb daYracxd%f:Ma /A'~Pxl agehrP7nMm kmNlMhYa. (n) '~','~%':rd tu(meas Mmbn ltlfibinlPmn wbn. MrNxniaourtl. Pn. Ic1 amr'Arid yal mana adr NMan+tbarmb allppllalla br dbr rrcam. I~ 'Certl'meun 4RYVm Gd711 Gdd ardaa RlPl~baad mmenrx bpamNanatn anxdau!mfoaa Myae NCaanA. 01 'nnwamrnsyrcn `rM CId1%Gatlnaad Tm a. 111 'LlredCretllr mane Pm axFraoYnisdwlNbdaal%wa malm areinhmmwur caul. i. 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Youn weaaxwtpaama intllT/OMMIMO)YM krs rmm msulba do rm dmrpa waled to al PNM Cm ]A6 a1x IR/ NPAI b 9tl ib M'! 1 aY nOm m adbl mN Iw GYPNFNYI.POlNI xFNENtr EXHIBIT "B" a aplb tlM m applbd m~puNra.adadinP bN irpNtl iN+e ~n9r il-cuuu uo~gr nn 1'ICCItl C.ttJ 1~1 GULLtU1fUlYA fllfybb2U( N, Ub/U( yz. 81A1888a8ApYI Mr mY ~O, ~ xill~Iy bla~ 18. IItl118 Yla 48aMA18 CABs Clwla cnaMune YUW.t CA A. Np Vlr Caanlenre CAxxn B, Dnlr Ma wrrn mnr lYIINI C. NgCa9eY9arzoCJrJw mu D. YA rrrj mnmAVbl CangO rlXYna Vlr OaOpppda GA 18. FIe110. 8rs8rr. Ramiro rrgl d rb eWImY b mblerle 9n lOni/l pinlLlap pr a'rb 16. AIIIBIIM IdMBIa. Nl an nar 16. IIa11dY Ipreel. i0 murewu peel Pb mRinlpn our 1(ONaBp a1+l.aarrlae.Nq- .r+M wa.tYtlMnlraA rerrMllMwrex/w v. wa a/aarCane. t%ero A. 88AYaIM vhl /llnrldn __, ., Vlle Gob..... __ _.... Ym+Clerk. wr Clrsip Aem Shaw. p. 48Y PAymem CAala. d' e. 8aH1A1N Gre88. X9adr, 1. IebmeI CMMIfM. Aai F. B~oAla1~A VIa OrIgNM1 11. WPaP~r /lla, VAme%eq . xdb Pamm~l Ore m etlma up I II. NIMw Arrr. Tnm Aea. PrA!bYaa Aaaum HwurdeBr lM r9mpxe exprlmw p4Y oniema CnUd dlydly xOpl pa AtmuM NI Yni Cpm99mm m rml a txHneO. oll wu N%aae bpm It, II ymr ArmW V In Oepu%, d ila Ca'0 a ary Vng f:Ormnlere Crete Mw peen raPdsl l6sl a sldn~ a Et0r m M mxuep brxlEn 'In nemlilEOriN h pilAd i~ US Dollar E91MI1x ABxI i, 8118 oeawrnm rW h OerMtlbne m e mxpn pne0tyrm r e rM WMM by Vir Imn Im Ye, YIIXIA nl9 mq rry Iran IA9 rdlc Viy iaM recaa, a rp panmr9nl mandaM rxq in MkCI M Aq dookedA apbx PNYIIXm 0119, Idlrltl b/ Onxrerypr. wp pamar Wlllp IM Adnunl. II rod rYglal, M MX nets 11FOpm hi rrglpl am dlhesp poor p1m11 MBrW a m Sax Awoum hn uo'890 a r dA10 M rm NBI19Bp1lap. IyYll YOUR BILLING RIGHTS -KEEP THIS FOR YGUR RECDRp$ Thle nda mrrlm InlpalrX Xmnrlbn ddaa you rghp pbM r9lmypmlflla NNbrlr fiV COmI Alllirq AEI. NDTIFY US IN CASE qF ERRORS pfl QUESTNINE A6pUT YOUR NIpMTIN,Y SII.LIN6 STATEMENT. M 1m~ntlrll pn nrOAnq' nIA1p.YmxrmbwmA a N lau nwd nmeiaymamlppre Ilxlrmpn En pYadrpMl, yalp Iln d98 mardoEd rrm n Ir adrer ICampY Ywerw9. IVaN m IpM xHi EpOnxrlfl. rM inlrtl ApV mm ypU m per XM 80dm9 xrrw axtl pulp Ihr xamrd m eaim tlpamr pramYm IPP9xm. muexl bYgmru, Wl gdlej xt wiYigl Pr9pr'd 9WI rjym. n rout Abp pro ul Nn MMWQ pbmgpl' • YaN npPlplA M'.WlAnrmper • The dElkammldtlle xepYlw nmr. Drink rp amxbxIXxel, Npu W Wry y(el rINYI rM is rhml. N Pu rysl Ayne irNarMbn.Uraih tlp Arr wu n M fan Aa92. d p~ Mwlu%1nIlAN u5 m V9P YaVmamdY dung erlmpn xanYnrlN Npmpn 9dtg1 mtneoiy AxdN, wri ran rop OY myarn a xry YmurY pl mks i9 rnAp, TO slgl hapira}i roar Idb mM ~axh r dem Ul lxsinro dra Odkn me aaw nrb pwlm ! 9dpIlA(Y b 4\T.Ir YpUR RIpNTS ANq OUR RESPONSISILITTE8 AFTER WE RECEIVE YOUR WRITTEN NDTN;E. r9e91nbwu mr Ilpplrun yW aerron.IrplutlNNJANa muga, naarnpprymyxrabxmoux xpM1r p, rmn limn. Imp xa aV in 0ad!ar n RdMXYI maaa mYam lou mry het ro ael Ilrre dyer. Yd Imu wX Iwe bmpYOpem more rnene m nYda- IJYI pllrMb r wMl blmy Mile rx Atl pr EW2n W ur My, w! mIM pl Ypdq+tr9pxl wJlrydq ypM1lpw aMlr nmpnmlw hvm awM hmay la Bnm d rmllry M. SPECULL RULE FOR CREDIT CARD PURCFIASE$. NYa AMIPmdxnpla%xnppnmp9peMa rr910.mfipy0p aimred 9eM aaknpn, W you AlNrla In Bpm MAbmmdlm Vrmhnxr tlpnprdrn. wullW rrlnnrbnl na mpry pa rrrnre 9moullrxwra naperNd9lrvktl. rkr M Aw ImlMme m m9 rqn: il) la+rm01 MwnMp BIn pdmFaa In epu bn ed a, U reY anro wrlr mvmeuY, xm8n Im MW nl IdE aumNmtiNne xbmr', and 1D18Y au0hil prlp mar hM hrn mon ran ESO. ThrOilllldan9 mM rPY/ II w pM a Ip9mn Vp Mer(Allll, Ur MNEmdYb y01111p drMlWl'dIl OJ91m plppary a amX. ' KARL M. LEDEBOHM ATTORNEY-AT LAW P.O. BOX 173 New Cumberland, PA 17070-0173 Phone: 717-938-6929 Fax: 717-932-0317 January ] 7, 2006 (Via Certified and regular mail) Jeffrey A. Brewbaker 920 Wertzville Road Enola, PA 17025 RE: Members 1st Visa Account No.: 4287590000361283 Dear Mr. Brewbaker: THIS LETTER AND ANY SUBSEQUENT CORRESPONDENCE FROM THIS OFFICE IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED MAX BE USED FOR THAT PURPOSE. AN IMPORTANT STATEMENT OF RIGHTS IS INCLUDED ON THE REVERSE OF THE SECOND PAGE OF THIS LETTER Members 15` Federal Credit Union ("Members lsi") has requested my office to collect the amounts due to Member's 151 under the above account. As you know, you are in default of your obligations under the above Members 151 Visa Account (the "Account") due to your failure to make the payments required under the Account in a timely manner. The last payment on the Account was received by Members 15` on or about June 24, 2005. As a result of your defaults, Members 151 hereby accelerates all amounts due to Members 151 under the Account and hereby demands the payment of all amounts due to Members 151 under the Account in the amount of $10,817.44 itemized as follows: 1. Principal $10,105.80 2. Unpaid finance charge 566.64 3. Unpaid N1A fees 30.00 4. Legal Fees 115.00 5. Total due to Member 15` as of 1/17/06 $10,817.44 If you fail to deliver to my office at the address set forth above payment of the $10,817.44 within thirty (30} days of the date of this letter, Members ls` will have no EXHIBIT !'C" choice but to file a legal action against you to collect all of the amounts due under the Account without further notice. In such event, in addition to the above amounts, you may also be responsible for the payment of additional reasonable legal fees and costs of suit incurred by Members I51 Nothing herein shall constitute or be construed as an agreement on behalf of Members 1 S` to accept any terms and conditions in exchange for payment of the amounts due under the Account except for the immediate payment of all amounts due to Members 1" . Nothing herein shall constitute a waiver of any rights or remedies which Members 1 S` may have under any written agreement or at law or in equity to collect the balance of the indebtedness due under the Account without further notice, including, without limitation, the right to accept and apply any partial payments made on the Account without waiver of any demand for payment in full of all amounts due under the Account. Nothing herein shall constitute an agreement on behalf of Members 1 s` to postpone or extend the maturity date of the obligation. Members ]S` looks forward to the payment of the $10,817.44 on or before Febmary 16, 2006. Very truly yours, Karl M. Ledebohm CC: David Thomas, Collections Officer NOTICE This letter is an attempt to collect a debt. It you dispute the validity of this debt, or any portion thereof, and you contact the undersigned within thirty (30) days after receipt of this Notice, you will be furnished with written verification of the debt; provided, that if a lawsuit has been filed against you to collect this debt before the expiration of the thirty (30) days, the complaint filed in said lawsuit will constitute written verification of the debt. If you do not dispute the debt or any portion thereof as stated above, the undersigned will assume the debt is valid. if the original creditor of this debt is different from the creditor stated on the front page of this letter, the undersigned will provide you with the name and address of the original creditor upon written request from you within thirty (30) days of receipt of this notice. The undersigned means the name signed at the end of this letter appearing in print ^ Complete Rems 1, 2, and 3. Also complete Item 4 if flestricted Delivery is desired. ^ Print your name end address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailplece, or on the front 'rf space permits. 1. Article Addressed to: ~y~z,~^- 1,z' ~ I~-, ~~ ~,~t~~U~~~~- 4~--v~e~o. ~'f} t~2S Article Number ^ AgeM B. Received by (Pn'nted Neme) 1 C. Data of Defivary 'D. Is delivery address tliRerent imm ttem 1? ~ Ve: If YES, enter delivery address below: ^ No 3. Service Type ~.CeRifietl Mail ^ Express Mail ^ Registered .Return Recalpt for Merohantlise Insured Mail ^ C.O.D. 4. Restricted Delivery! (Exfre Fee) ^ yes _-. 7mf1LL aA4fl nnna A47~ ~4F,3 MEMBERS 1ST FEDERAL IN THE COURT OF COMMON PLEAS CREbIT UNION, formerly CUMBERLANb COUNTY DAFCU PENNSYLVANIA PLAINTIFF Vs. NO.: .TE.FFRE'Y A_ BRE'WBAIZFR DEFENDANT. :CIVIL ACTION-LAW VETt)<FTCATTOIV I, David Thomas, Collections Officer for Members ls` Federal Credit Union, being authorized to do so on behalf of Members 1St Federal Credit Union, hereby verify that the statements made in the foregoing pleading are true and correct to the best of my information lmowledge and belief. T understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. Members 1" Federal Credit Union Sy~ ~~J 1. ~'~x~~.~[~ David Thomas, Collections Officer ~ ~J ~- ~~ °` h' ~ ~ ~~ u'4 `~ MEMBERS 1sT FEDERAL CREDIT UNION, formerly DAFCU Plaintiff v. JEFFREY A. BREWBAKER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.06-1153 Civil CNIL ACTION -LAW ANSWER TO COMPLAINT AND NOW, comes the Defendant, Jeffrey A. Brewbaker, by and through his counsel, Cunningham & Chernicoff, P.C., and files his Answer to Plaintiff's Complaint as follows: 1. Admitted. 2. Admitted. 3. Denied. This allegation refers to a writing which has been attached to Plaintiff s Complaint and such writing is the best evidence concerning Plaintiff s averment. 4. Admitted. 5. Denied. This allegation refers to a writing which is the best evidence concerning Plaintiffs averment. 6. Denied. This allegation refers to a writing which is the best evidence concerning Plaintiff s averment. 7. This allegation is a conclusion of law to which no response is required. 8. Denied. This allegation refers to a writing which is attached to Plaintiff s Complaint and such writing is the best evidence concerning Plaintiff s averment. 9. This allegation is a conclusion of law to which no response is required. To the extent that a response is judicially deemed required, it is specifically denied. By way of further answer, Defendant believes, and therefore avers, that all payments made to date may not have been properly credited and a strict accounting of all payment received, applied, and alleged to be due and owing is demanded, if relevant, at the time of trial. Defendant further specifically denies the amount set forth for legal fees as Plaintiff has not set forth how such fees were calculated nor has Plaintiff established that such fees are fair and reasonable under the circumstances. Furthermore, it is believed, and therefore averred, that such fees are not reasonably related to the difficulty or extent of work necessary to complete the litigation initiated in this matter, and strict proof thereof is demanded, if relevant, at the time of trial. 10. Denied. This allegation refers to a writing which as been attached to Plaintiff s Complaint and such writing is the best evidence concerning Plaintiff s averment. 11. Denied. This allegation refers to a writing which as been attached to Plaintiff s Complaint and such writing is the best evidence concerning Plaintiffs averment. 1 I . (Sic). Admitted in part; denied in part. It is admitted that Plaintiff has made demand upon Defendant to make payment. It is specifically denied that the amount set forth in Plaintiff s Complaint are due and owing to the Defendant. By way of further answer, Defendant believes, and therefore avers, that all payments made to date may not have been properly credited and a strict accounting of all payments received, applied, and alleged to be due and owing is demanded, if relevant, at the time of trial Furthermore, Defendant specifically denies the amount set forth for attorneys fees as Plaintiff has not set forth how such fees were calculated nor has Plaintiff established that such fees are fair and reasonable under the circumstances. Furthermore, it is believed, and therefore averred, that such fees and costs are not reasonably related to the difficulty or extent of work necessary to complete the litigation initiated in this matter, and strict proof thereof is demanded, if relevant, at the time of trial. WHEREFORE, Defendant, Jeffrey A. Brewbaker, hereby respectfully requests that this Honorable Court dismiss Plaintiff s Complaint with prejudice and grant Defendant such further relief as is just and proper. By P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 Date: APfi ~ 3, ao~lo Attorneys for Defendant homeAtlf~enswusAbrewbake Kelly M. Knight, Esquire I.D. #87365 2320 North Second Street MEMBERS 1sT FEDERAL : IN THE COURT OF COMMON PLEAS CREDIT UNION, formerly DAFCU :OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : N0.06-1153 Civil v. :CIVIL ACTION -LAW JEFFREY A. BREWBAKER, VERIFICATION I, Jeffrey A. Brewbaker, verify that the statements made in the foregoing Answer to Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date:.'r1Qfi 13, aoel~ MEMBERS 1sT FEDERAL CREDIT UNION, formerly DAFCU Plaintiff v. JEFFREY A. BREWBAKER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1153 Civil CIVIL ACTION -LAW CERTIFICATE OF SERVICE I, Stacy A. Sollenberger, Secretary with the law firm of Cunningham & Chernicoff, P.C., hereby certify that on the ~ day of ~} P(, y, 2006, a true and correct copy of the Answer to Complaint was served byfirst-class U.S. Mail, postage prepaid, to: Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 CUNNINGHAM & CHERNICOFF, P.C. BYE- Q_ ~U2~~~2O~21CAlUt Stacy A. S ]lenberger (~~ 2320 North Second Street P. O. Box 60457 Harrisburg, PA 17106-0457 ^U ~~ :5 .. t~ tJ'i • ~7 f. SHERIFF'S RETURN - REGULAR CASE NO: 2006-01153 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MEMBERS 1ST FEDERAL CREDIT UN VS BREWBAKER JEFFREY A ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BREWBAKER JEFFREY A the DEFENDANT at 1512:00 HOURS, on the 1st day of March 2006 at 920 WERTZVILLE ROAD PA 17025 by handing to DEBORAH BREWBAKER, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 13.20 Postage .39 Surcharge 10.00 .00 41.59 Sworn and Subscribed to before me this ?l.af day of Pro tary So Answers: ~~~ ,~~ R. Thomas Kline 03/02/2006 KARL LEDEBOHM By: d Deputy S eriff Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS is FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION, formerly CUMBERLAND COUNTY DAFCU PENNSYLVANIA PLAINTIFF Vs. NO.: 06- 1153 Civil JEFFREY A. BREWBAKER DEFENDANT. :CIVIL ACTION-LAW PETITION FOR THE APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Karl M. Ledebohm, Esq., counsel for the plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is TWELVE THOUSAND ONE HUNDRED TWO AND 44/100 ($12,102.44) together with additional attorney's fees and costs of suit and interest at the legal rate an and after the entry of judgment. The following attorneys are interested in the case as counsel or are otherwise disqualified to set as arbitrators: Kelly M. Knight, Esq., Robert E. Chernicoff, Esq. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. _ OF COURT AND NOW, , 2006, in consideration of the foregoing petition, ,Esq., Esq., and ,Esq., are appointed arbitrators in the above captioned action as prayed for. By the Court, P.J. ~9. ~ ~ ,~ a ~ ~ ~ ~ . i ~~ G3 -~- rj'+ i.. ~ `~; ` W _ ` `Y=~~ r -~- _ ~~ ~~~~~ .. ~_~} . ~ ~• ..~~5 Karl M. Ledebohm, Esq. P.O. Box 173 New Cumberland, PA 17070-0173 (7171938-6929 MEMBERS 1sT FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION, formerly CUMBERLAND COUNTY DAFCU PENNSYLVANIA PLAINTIFF Vs. NO.: 06- 1153 Civil JEFFREY A. BREWBAKER DEFENDANT. CIVIL ACTION-LAW PETITION FOR THE APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Karl M. Ledebohm, Esq., counsel for the plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is TWELVE THOUSAND ONE HUNDRED TWO AND 44/100 ($12,102.44) together with additional attorney's fees and costs of suit and interest at the legal rate an and after the entry of judgment. The following attorneys are interested in the case as counsel or are otherwise disqualified to set as arbitrators: Kelly M. Knight, Esq., Robert E. Chernicoff, Esq. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall hP e»hmiltP~1 AND NOW foregoing petition, Esq., and appointed arbitrators in the above capt: e es ~~ ~ , d ~m , E~ Coy' ~(~.~ ~~ ~n~9ht , Es`~ Ke~~~ q_~~-D(a ~K~ 2006, in nsideration of th ,Esq., _ ~'N . Esq., are action as pra ed for. By th ourt, ~_ .J. ~ ~ ~ O ~ d ~ ~ ~ Q r .~- - T~:_- ~' ~ 'T_' ""l C7 ~ ;~ _, `'LL ~.~~~ -- ~_ _ _~ , k~~ _, ~_ .: ~ _ .. ..,. ~'1 jy .. ,. ~i.,l-f Q' .~ •~ N"'~ ! s MEMBERS 1St FEDERAL, CREDIT UNION, formerly DAFCU ~~ Plaintiff v. JEFFREY A. BREWBAKER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1153 CIVIL TERM CIVIL ACTION -LAW PETITION TO VACATE ARBITRATOR 1. On or about September 7, 2006 by Order of Court Galen R. Waltz was appointed as an Arbitrator in the above captioned case. 2. Galen R. Waltz represents Richard Yinger in a case that involves termination of parental rights. By Order of Court dated September 20, 2006 the Petition for Involuntary Termination of Parental Rights was set for hearing for Wednesday, December 13, 2006 at 9:00 a.m. in Courtroom No. 3 before The Honorable Judge Guido. 3. By a letter of October 6, 2006, the Petitioner was advised that the Arbitration Hearing was set for Wednesday, December 13, 2006 at 9:00 a.m. WHEREFORE, the Petitioner requests his appointment as an Arbitrator in the above case be vacated and that The Honorable Court appoint a replacement Arbitrator. Respectfully submitted, en R. Waltz, qui Turo Law Offices u 28 S. Pitt Street Carlisle, PA 17013 (717} 245-9688 C~J m t ~a ~ ., _.. -.rJ -; t W ~ ".~ .. ,. ~•,J =~ . ,. MEMBERS 1St FEDERAL, : IN THE COURT OF COMMON PLEAS OF CREDIT UNION, formerly :CUMBERLAND COUNTY, PENNSYLVANIA DAFCU Plaintiff OCY 1 ~ X006 v. : NO. 06-1153 CIVIL TERM JEFFREY A. BREWBAKER :CIVIL ACTION -LAW Defendant ORDER OF COURT AND NOW, this /~ day of C~~(ti , 2006, in consideration of the foregoing Petition, ~~ ,Esquire is appointed as a replacement Arbitra r in the above captioned act n as prayed for. BY THE COURT, ,, 1 Gvl Edgar B. Bayley P.J. Cc: ~ f3'a~en R. Waltz, Esquire ~bert M. Walker, Esquire ~" orge B. Faller, Esquire ~rl M. Ledebohm, Esquire J ~y M. Knight, Esquire Cs., ~ J~9u..,.:v- r. ~ ~= ~ tis,t .r ~_ ;:~ -~ ~ ` ~ ° ~W r p i '~- O r`~-a C? Members 1st Federal Credit Union, formerly DAFCU In The Court of Common Pleas of Cumberland Jeffrey A. Brewbaker Plaintiff County, Pennsylvania No. 06 - 1153 Defcndant Civil Action -Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. ignature tore tore George B . Faller, Jr . , Esq . ~o~j.~~"_~llt~~~GL ~o s.c~~ ~ , TS;,~,~ k~ Name (Chairman) Name Name Martson Deardorff ~ y~~~ ~ ~,o W i 11 i ams & O t t o ~Q {~~ v~,pr~/,. ~/ ~ C Lr}~,i1 y~ `~ o F ~7"c:ts tY~~t bl ~h Law Firm Law Firm Law Firm 10 East High Street `~~ ~~~~(~~; ~Z3? ~~(~ ~~1L~z__ Address Address Address Carlisle, PA 17013 ~ ~- ~~~~ C~n~~ ~ ~ ~a i3 City, Zip City, Zip City, Zip ~ 1118 3 #~ I I ~f3- ~ I b3 ~9 Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed}, make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) In favor of the Plaintiff in the amount of $12,102.44, plus interest and costs. .Arbitrator, dissents. (Insert name if applicable. Date of Hearing:, Date of Award: Notice of Entry of Award Now, the l~~h day of , 20 D(Q , at D~ , ~.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ a90 , ~° By: Deputy 12/13/06 12/13/06 .~~+• ~~~ ~° '~ ~' «'" ,t~ ~~ ~ ,a~ d~~ iC j~l' ~~ ~°"' ~~ C3 ~f`t ~~ ~.,..' - _ --,~ __ _~ _~_ - - ~ C ° -; ~ ' _ L~ ~; _~~ ~ . r ~~ ~~ ' ~1 Members 1st Federal Credit Union, formerly DAFCU Plaintiff Jeffrey A. Brewbaker Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 06 - 1153 Civil Action -Law. Oath We do solemnly swear {or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. ignature tore tore George B. Faller, Jr., Esq. Name (Chairman) Martson Deardorff Williams & Otto Law Firm 10 East High Street Address Carlisle, PA 17013 City, Zip /CO //7- llr~~~ Name ~~ Law Firm ~~e~ ~~~~--~v Address City, Zip Name Law Firm 1 L3 ? ~ ~ l c... I~~ ~-- Address Cz.clr~b lQ ~- t ~ 0 ~3 City, Zip ~ 1118 3 ~' 1 ~'~.31 # lb3~9 Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) In favor of the Plaintiff in the amount of $12,102.44, plus interest and costs. .Arbitrator, dissents. (Insert name if applicable.) ~,~ Date of Hearing: 12 / 13 / 06 Date of Award: 12 / 13 / 06 Notice of Entry of Award Now, the ]'~~h day of , 20 D~Q____, at 0~ , ~.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ aqp . ~° By: Deputy ~~, ~~, ~ 1 ~ l~a`4 ~e. ~~~~ ,~ ~~ ~~d ~°~ r,a ~~ ~ a 1` t- a ~ ~m _, ~... -;~_ ,- , ~ C~ - [,T' y ra --C ~a Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 ~ ` FEDERAL CREDIT UNION, formerly DAFCU PLAINTIFF Vs. JEFFREY A, BREWBAKER DEFENDANT : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.:06-1153 CIVIL ACTION-LAW PRAECIPE TQ ENTER JUDGMENT To the Prothonotary: Please enter judgment in favor of Members 1~ Federal Credit Union, formerly DAFCU and against Jeffrey A. Brewbaker on the Award of Arbitrators in the amount of $12,102.44 together with interest at the legal rate from the date of judgment and costs. A copy of the Award of Arbitrators is attached hereto as Exhibit "A." No appeal has been filed to the award and more than thirty (30) days has elapsed. Date: January 16, 2007 Re ub , C Karl M. Ledebohm, Esq. Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ~ .: s Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-4173 (717)938-6929 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. SECTION 101 TO SECTION 149 ETC. MEMBERS 1sT FEDERAL CREDIT UNION, formerly DAFCU Plaintiil' vs. JEFFREY A. BREWBAKER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 06-1153 Civil Term Amount Due: $12,102.44 Interest from: 1/19/07 at legal rate Atty's Com. N/A COSTS TO BE ADDED TO THE PROTHONOTARY: ISSUE WRIT O~ EXECUTION IN THE ABOVE MATTER (1) Directed to the~~l Pennsylvania; (2) against Jeffrey A. Brewbaker, 920 Wertzville Road, Enola, PA 17025, Defendant; and (3) against First National Bank of Marysville, 2 Centre Square, Marysville, PA 17053, Garnishee; (4) and index this writ (a) against Jeffrey A. Brewbaker, 920 Wertzville Road, Enola, PA 17025, Defendant; at~d (b) against First National Bank of Marysville, 2 Centre Square, Marysville, PA 17053, Garnishee; Members 1st Federal Credit Union, formerly DAFCU In The Court of Common Pleas of Cumberland Plaintiff County, Pennsylvania No. 06 - 1153 Jeffrey A. Brewbaker Defendant Civil Action -Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. ignaturc tore tore ^~ George B. Faller, Jr. , Esq. ~Ce~j ~!<<~~~ ~°~~ ~ • !~~-KC~"q Name (Chairman) Name Name l Martson Deardorff Williams & Otto Law Firm 10 East High Street Address Carlisle, PA 17013 City, Zip ~ I I'l8 3 Address ,~ ~~y~ City, Zip ~ r~~31 Award Law Firm 1 z-3 ~ lrl-o tic., 1~~ ~L~... Address Cz.~.~.~a ~. RA- c ~ o ~3 City, Zip ~ !b3 ~9 We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) In favor of the Plaintiff in the amount of $12,102.44, plus interest and costs. - -- _ .Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: Date of Award: ..1 C~ /~ Law Firm Notice of Entry of Award //a - ~~ yo-~ yo - Now, the ~~~h day of ~ , 20~, at ~~sa , ~.M., the above awazd was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $_ _~gp . °, By: zothonotary 12/13/06 12/13/06 Deputy ~' ~ c `~ ~~ ~`",~. ~a`' ~' ~~ ~`' ~~ p~fi CP ~~~ ~ C 1 c~..,a' C~ ~ ~" -r .` r .~"" . %= ~ _.P ~ , ~: - t'r~ .... t 3'~ .~~ ~ 1 '~ ,, and levy upon any and all personal property of the defendant (s) as follows: Any and all personal property of the Defendant in the possession of First National Bank of Marysville located at 2 Centre Square, Marysville, PA 17053, as Garnishee, including, without limitation, any and all funds on deposit. (c) Exemption has (not) been waived. Dated: ~ ' ~ r cd ~- (717)938-6929 Attorney for Plaintiff ~ Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 c; . t 6' Z u ~~'- ~Q. C~ .~, ~, ~ ~ c ~ ~, ~-; ~ } ,-4 c ~ ~ ~` ~> ~ ~ ~ - .. ~ ~ ~"- ~ ~ ~ ~ ' ~ ~~ ~ ~^ _.~ .,. '~ ~ w '^ 'y !~ _ _ ~"' w `~~~ ~ -. WRIT OF EXECUTION and/or ATTACHMENT ~. . ~ COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF PERRY COUNTY: To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION, FORMERLY DAFCU, Plaintiff (s) From JEFFREY A. BREWBAKER, 920 WERTZVILLE ROAD, ENOLA, PA 17025 (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 ANY AND ALL PERSONAL PROPERTY OF THE DEFENDANT IN THE POSSESSION OF FIRST NATIONAL BANK OF MARYSVILLE LOCATED AT 2 CENTRE SQUARE, MARYSVILLE, PA 17053, AS GARNISHEE, INCLUDING, WITHOUT LIMITATION, ANY AND ALL FUNDS ON DEPOSIT. 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 $12,102.44 Interest FROM 1/19/07 AT LEGAL RATE Atty's Comm Atty Paid $139.09 Plaintiff Paid Date: FEBRUARY 5, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs Curti R. Long, P ~ ~y By: NO 06-1153 Civil CIVIL ACTION -LAW Deputy REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: P.O.BOX 173 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 -,. Kazl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (71738-6929 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.RC.P. SECTION Ipl TO SECTION 149 ETC. MEMBERS 1sT FEDERAL CREDIT UNION, formerly DAFCU IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. JEFFREY A. BREWBAKER Defendant 06-1153 Civil Term Amount Due: $12,102.44 Interest from: 1/19/07 at legal rate Atty's Com. N/A COSTS TO BE ADDED TO THE PROTHONOTt~RY,~,~ISSUE WRIT OF EXECUTION IN THE ABOVE MATTED (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Jeffrey A. Brewbaker, 920 Wertzville Road, Enola, PA 17025, Defendant; and (3) against N/A Garnishee (s); (4) and index this writ (a) against Jeffrey A. Brewbaker, 920 Wertzville Road, Enola, PA 17025, Defendant; and (b) against N/A Garnishee(s); and levy upon any and all personal property of the defendant (s) as follows: Any and all personal property located at the address of the Defendant, Jeffrey A. Brewbaker, at 920 Wertzville Road, Enola, PA 17025, including, without limitation, any vehicles of Defendant. (c) Exemption has (not) been waived. Dated: 3 -~= o ~- earl M. Ledebahm, Esquire 'Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ~, '~- ~, ~ k ~ ~ ~ o~ Z "'`~ 14 ~ ,~ ~ ~ ~ `'t ~ _ i '~ O ^4 ~ ~ 1 rT~ . ` i r-, T _ , ~ b7. ~ . ~ ~ti __f - ._, r~ f' ~ ~- WRIT OF EXECUTION and/or ATTACHMENT , ~ - -• COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1153 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MEMBERS 1sT FEDERAL CREDIT UNION, FORMERLY DAFCU, Plaintiff (s) From JEFFREY A. BREWBAKER, 920 WERTZVILLE ROAD, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ANY AND ALL PERSONAL PROPERTY . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $12,102.44 Interest FROM 1/19/07 AT LEGAL RATE Atty's Comm Atty Paid $154.09 Plaintiff Paid L.L. $.50 Due Prothy $1.00 Other Costs Date: MARCH 6, 2007 (Seal) REQUESTING PARTY: Name KARL M. LEDEBOHM, ESQUIRE Address: P.O.BOX 172 NEW CUMBERLAND, PA 17070-0173 Attorney for: PLAINTIFF Telephone: 717-938-6929 Supreme Court ID No. 59012 Curt s R. Lon not By: Deputy