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Home My WebLink About06-1175ARBITRATION 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 (215) 789-7151 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. GERALD N SNELL 109 Iron Stone Rd New Cumberland, Pa 17070 NOTICE 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 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 relief regncsted by the plaintiff. You may lose money or property or other rights important to you. Defendant(s). Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. C) O 1. ?(ULLTE CIVIL ACTION COMPLAINT AVISO Le han demandado a usled en la carte. Si uslcd quiem defenderse de estas dernandas expuestas to ]as paginas siguienles, rated tier veinte (20) digs de plazo al partir de Is Reba do la demanda y la notification. I lace falta ascula, una comparencia escrita o on persona o con en abogado y entregar a la torte on forma escrita sus defensas o sus objeciones a las demandas en contra de so persona. Sea avisado quo st usted no se defieude, la corte lomara medid'as y puede coutinuar la demanda on contra suya sin previo aviso a notificacion. Aderras, Is torte pucde decidir a favor del demandante y requiem que usted cumpla con today [as provisioner de eses demanda. Usted puede Fender dincro o sus propiedades u ourm dercehos impounnues pars usted. YOU SHOULD l'AKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPI(ONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LI.EVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTF,. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR I ELEFONO A LA OFICINA CUYA DIRECCION SF, I'NCUENTRA ESCRITA A13AJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, 13A 17013 (717) 249-3166 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 Plaintiff, V. GERALD N SNELL 109 Iron Stone Rd New Cumberland, Pa 17070 Defendant(s). ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No.OL - //7S (?,0L- ,? CIVIL ACTION COMPLAINT 1. Plaintiff, Ford Motor Credit Company, is a Corporation with its place of business at P.O. Box 6508 Mesa, Az 85216-6508. 2. Defendant, Gerald N Snell, is an individual who resides at 109 Iron Stone Rd New Cumberland, Pa 17070. 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 July 29, 2004, 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 $27,409.26 at an annual percentage rate of 8.540%, in order to purchase a certain motor vehicle, 2004 Ford F350 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 $564.74 for a period of 60 months until the loan was paid in full all as is more fully set forth in the Contract. 6. Defendant(s) made monthly payments until July 12, 2005, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 7. As a result of the default by Defendant(s), and pursuant to the terms of the Contract, the above-mentioned vehicle was repossessed and a notice of repossession was sent to the Defendant(s) giving the Defendant(s) the opportunity to redeem the Vehicle as well as notice of the sale date. A copy of the notice of repossession and notice of sale date are attached and marked as Exhibit B. 8. The Defendant(s) failed to redeem the Vehicle and the Vehicle was sold at auction with a credit given to the Defendant in the amount of $19800.00, however a balance of $3304.20 is still due and owing, and a notice of the deficiency balance was sent to the Defendant. See copy of the notice of the deficiency balance attached and marked as Exhibit C. 9. Pursuant to the terms of the contract, Defendant is required to pay all amounts due and owing, including any balance that may remain after the sale of the vehicle, and the Defendant failed to do so, thereby in default of the Contract. 10. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to $126.01 and which will continue to accrue. 11. The total amount due and owing at the time of the filing of this complaint is $3430.21. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $3430.21, well as any additional interest and costs that may accrue and such other and further relief as this Court may deem equitable and just. 'P.C. THOMAS R. DOMINCZYK, ESQUIRE Attorney for Plaintiff VERIFICATION I, THOMAS R. DOMINCZYK, ESQUIRE, verify that I am the Attorney of record for Plaintiff, FORD MOTOR CREDIT COMPANY, and duly authorized to make this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. BY: THOMAS R.1pOMINCZYK, ESQUIRE DATED: January 27, 2006 It- 34"390' 07129104 PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRA DATE m•ee) n ?.lS BG/er GERALD N SMELL C LL Nsnea eM AddNN pridubp Donq N2100001) CnrU SUTLI LIFF (amRer CAPITAL FIND /rFF t09 IRON STONE RD JUL 3 1000 PAXTON ST PO BOX 1737 0p? NEW CUMBERLAND PA 1707 0 2CPf HARRISBURG PA 17106 RJ r«. a. ammo Pea CsaNwrN?,rF mgauywrMNNeNerMa 1aaaM sash w «vaIX TN'dese rNa'sNSan MM YYa nnadN Sea wnWe. tla TrW YY NM• eiwn Mts. Y MM1Y PYn M WnMMtlb aW4enL ImY elbe« b Mn «<IWII MFNe BMMYe «O.ea9«a GYta NNMCM yym n N USED 04 FORD F350 P1C N/A IFTSF3IL6/EA11790 ? ?°W ?Ap10w°? OW? 13 IIe,manoa Twee 90FOR0 F250 PICKUP { 3000.008 N/A *=RANGE YM w lease Qrosa mPw A a once YOU MAY OBTAIN VEHICLE INSURANCE ITEMIZATION OF AMOUNT FINANCED FROM A PERSON OF YOUR CHOICE. 1. Can PH" ....... ........ .._........... _.._....... ........... _..... ......... ........ _..... $ 2 Dee" P'ylo'n R/A Third Party ReNW Asaloned m Creditor ...._ ................ 5 700.00 Coal DDo"VO31d6`...... ..... __...... ...,,.M f--9BDa:DD r...eew oa. a.«+ w 0ma Total Dean payment _._........._._.. 1,3700.00 Of 0. Unpdd DOW "of Cash Price (l mYm a 2)....___..._._............. _. f (f) 4. AmeuMS paid on your emaN (Se1Nr may be rn{Inlne Of portion of these empun16) To Inn nanu CompanNo M S %/A Onion We Ineunnce par him d..VW...._._...._...._.. ------ W7K OWbllny INWHINV a (W lore d Woad)............ $ Renn-aloneIEeaneN y?A To Punk Omcl.Is 0)101Ib"e ($ ?--1. '1 22. 0 51, it re Nr RON nme , 1.163. 1 fees S 176.60 (Ip teen i 6.00 (IM) br mxu lrbl in C+en Prka) S 16JJ.76 y 1768.26 11 - To Total _......._ ...................... FEDERAL CENTAOE I CHARGE I Financed I Payments RATE TN done, wean Tn..man a tN aeon ud a ON Maio." ereaY pnnnaad b yvu M Ma ea a yrry lima men t°u Oensll mob N Mwdubo Total Sale Payment Sd ichdo Non of Amount of Each NNn pspnsnY ET Parents Psym m moduo Yow payment schedule da 5 661.74 (.="** ell N: 11,41 S 564.74 09l1212MA O wu wa not N« to pry a pameany. on tlN portion of aedl pnnnard reoNo more IN orb amount or WK.p0 „,timer N Ian. dwW In da wI1ICN Nllb omnNaaad. V, .m,mtIn YOUTHE(/?RBITRATION PROVIUSIOONVON THE MZVFA3E SIDE OFOTHIS OONTRA . NOTICE TO SLYER Do not Sign this Contract in Wank. You are entitled to an exact oopy of the DontraCl You sign. Keep If to protect your legal rights. Buyer (and Co-Buyer) =knowledge that (I) before sidnino this [IUe e i c? onbris Buyer (and C"Riyar) received anD revlews0 ¦ plately filled in Copy of this contract and (II) at the t_l? offaal Canino this contract, Buyer (and Co-Buyer) nceTaa a roue and Domp y in copy of tRl8 contract BUYER aWFAI BqW ar amnbp eemoN. to aeaw s«Pr moonmax. anoolYer Aaalfrawk,mm? lneeapram eMt,mwd allnNd m nu aerraet tN aser naleN n W Ina ram, in. By TRA N,wr+wm Ir?wYm Nnew.rsucl mSACK THIS CONTRACT DOES NOT 11 UASIIATY INSURANCE OOVERA BODILY INJURY AND PR DAMAGE CAUSED TO OTHERS. ? Credll ule Meurer S N/A Premium Ineured(s) Signalurs Credl ? Disability IneUror f NIA Premium n-- ? cured SI nature OINr Optional Ineurende Tenn 6 MIA Insurer Premium nor ure unit tAe «d coon dewq am.uawe w ror tN lido a the c«Uad. Te.. lawn «a ee vrsgae w Mown In • mew w qww«t ew« m yw brier. You mot Inn, IN rshkY. S • dealt, Is almwn bdw Be CWW WII %.W euy tlN oewrsesss? ebswM W the mew. M" n a"W Wi111rare d? lar,6 bw me, sawi , Can ace an" a IN polar. XO Caner««slwxO y_.NApwnmub, l CCaaMpsbn ? Rre and Lan AbnbM LoNnt, ? T , and p T. mold T. Neonllea IEa«Nml PmeMVn { R-P7IL. Y beAStl pea Mw padNM s dsei aptlaW wd«d ehar. rapMa m a 1Nglmv,spe lab M b the the dapbd ram 00"tMVifa„„Mm armed edeWan Mom Y Yeeartl w Poe for N daH MoNwm no N owed. The .aLem Y M bT « Na aoMltl Im Ya nwNrW« a wow aYmuaaa uWw Srtlm e. Program No. OUESTIONSt PLEASE CALL US AT 1- 727-7000 do VISM lie st yYNN.fofdnredlLCdrlt Man ORIGINAL ---PRN- Ford Motor Credit Company P.O. B. 3076 COLUMBIA, MD2104543079 (al 67 4730 R1110I002oW33 GERALD N. SNELL 109 IRON STONE RD NEWCUMBERLAND PA 17070 Oataa Ratwsairl 07-11-2005 oats if Nake 07-12-2005 Dale of Conlnot 07-242004 Account Number 037429549 Buy, GERALD N. SNELL Cdgyea DESCRIPTION OF PROPERTY Year 2004 Make FORD ? Nev, Used Vehicle Idenkrsation Number 1FTSF311-64EA11710 MCtla F390 Bod 4%4 NOTICE OF OUR PLAN TO SELL PROPERTY we have your properly described above because you broke promises in our agrsemerd. ? PRIVATE SALE: We will sell the property described above at pnvale sale sometime after 15 days from the Delft of Notice Mown above unless redeemed by you prior to such sale. PUBLIC SALE: We will "lithe property describod above at publb sale to the highest bidder on the data belew (or any ad Wrnment date). The sale w N be teltl astdbws: Data of sale Thee of sale Place of Sale Y. may attend the souk and bnkg adders it you want. The money that we get from the sale (after paying our costs, including reasonable attorney's fees and legal expenses if permitted by law) will reduce the amount you owe. If we get less money than you owe, you will still owe us the difference. If we get more money than you owe, you will get the extra money, unless we must pay it to someone else. You Can gel the properly back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. See How To Get Your Property Back for an itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number above. If you need more information about the sale call us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you awe us, you may call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money unde your agreement. 1) The toyer and any cobuyer named above; 2) Any dealer/original Creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. The property is presently stored at BEN RECOVERY ETTERS PA HOW TO GET YOUR PROPERTY BACK To got your property back, pay us this a mount by earthed check or money order before the vehicle is sad. Unpaid Balance $ 24900.45 Plus Costs. Repo Expenses $ 175.00 $ $ Plus Late Charges $ 22.59 Lass Finance Charge Rebate $ Less Insurance Premium Rebate $ TOTAL $ 25,17603 (Plus expense incurred if default at the lime a repossesabn sxceetlM 15 days and Was rebate received after the date of this notice) Ywr property wont be sold until 1s days after the does of this nice at the EARLIEST. After Mel you can still get 4 bark any ikne before Its actually sokl. It you do, we'll have no further claim on a. But the Iapar You Ma, the more ware (Including repro s) you may have to pay. If you have any questions about this, please call us. ? The property has been (or will be) retume0 to: (dsaler/odglnd orWftor) Under our agreement wM your dealer/odginel crei ft Josken gNu aeddar h io aeli the pfopedy and pay you an, Manor left over. If youawe money after the sale, you will pay it to the deakenodpinal credtor. ? PERSONAL PROPERTY: Any personal Property found in the vehicle may be recaimed by youwithin the neat 90 days .,in accordance An sale law, by contacting this office. Thereafter, the personal property shall this dis oudi of accordingly (] Creditor hiss easigned to no qualified interracial (OI Exchange, LLC) its agMa (red not its obligations) witit respect to the sale of each vehicle listed above PAYMENTS: All payments to us most b by cori check a it" order. MILEAGE DISCLOSURE'. It you ere aware that the mflsapa reibaed on ate vehicle's otlometer k not accurate fa arty reason, dnea contact us eo that we can accurately report the vehicles mileage. INSURANCE RIGNT&. II you own ware to get your property back, cell the insurance company or the dealedongiral creditor to make sure that any insurance hoe been cancelled. You have a right to get credit for all pramlum refunds. JESSICA A SNYDER crux rdme-97 ?anax Fixwa witiane mvy uo*a cease. CUSTOMER/CUSTOMER FILE 1. mu s A. A4 0? Nm.1 .eMa: Cf k I AI6v SIIXn N.n S...ar6.AfM N. ad 38120 Amrhein 1M 7p. IX °? , a ,, 00, . j1M G , FF M1 48150 Livonia ° -,? o . ? n•ay*.d 0 wwm6wrra M wmw T a a .arX?r WFM.raX•r6 ?JU L 122009 , ' I L7 6'Vw MJ ? 91yI.MV CaATM1T HVIIIIYk Yi// Arntl.Mm4r I /U>r M1^M 9Ft OY..AY6 DPQgV Pu1FY __ _ Fw _ Mu:gMY AduYVW. XP.pItlYM Irsur.E _VYy nw 6wAr OC sc SM F9: m XCCU F. {4 FN FM U0711120626965 -- -- - -- - - - . 3? .3 CB.023876866 1 TIMOTHY K. JOHNSON 7004 2510 000D 0598 8151 1 440 GLEN MILL ROAD - 1 THORNTON PA 19373 ---, - ---- ----- U0711mub9t u - I FL-037109338 TIMOTHY J. LISSON 71704 25117 0000 0598 8166 - U0711/47724269 7004 2510 0000 0596 8199 _ 12172 COPELAND RD BUCKTAIL LODGE _ ?T- - - SOLANSPRINGS WI 54873 -- PO BOX 76 W TPORT PA 17778 j6 U0711/20526987 7004 2510 0000 17598 6175 `?7]4f20526970 41 u HB-M568733 V' 74265,19 7004 2510 0000 0598 B2p5 STANLEY R. GIBSON -^- GERALD N. SNELL -- -- 5 205 SPENCERVILLE 109 IRON STONE RD •- I I E HICKSVILLE OH 43526 NEWCUMBERLAND PA A C 1 1 dR. 1\ O I E 2: w 6 U0711/20526968 7004 2510 0000 D598 8182 JJ-036787366 7 SHANE O. SELTZER ------- - ---- 301 SOUTH MAIN STREET JERSEYSHORE PA 17740- - - - - - - S.. PFlvacy Act Stal.m.n1 on R.wr.. PS Form 3677, F.6.n, 2012 (Pros 'a2) Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 21045-6076 800 6770730 DATE: 2005-08-17 P0206H00000092 GERALD N. SNELL 109 IRON STONE RD NEW CUMBERLAND PA 17070 STATEMENT OF SALE Account Number: 037426549 The following property has been sold. Year Make Model Vehicle Identification Number: 2004 FORD F350 1FTSF31164EA11790 Balance owing on your contract (1) $ 25,003.03 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ _ 25,003 03 Deduct: gross proceeds of the sale (4) $ 19,800.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 5,203.03 Add: Expenses of retaking and storing, and (6) $ _ 367.00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (7) $ 0.00 (8) $ 2 265.83 Other _- (9) $ .20 3304 Deficiency'* Surplus' (10) $ N/A The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses 8 interest added to your account (debits). Surplus' or Deficiency` ' If the sale resulted in a surplus, a refund for the difference will be mailed to you. If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for payments shown below. For additional information call or write: Mail deficiency payment to: Ford Motor Credit Company Ford Motor Credit Company P.O. BOX 6508 DEPT 194101 MESA ARIZONA 85216-6508 P.O. BOX 55000 (800) 732-2264 DETROIT MI 48255-1941 FFNA11M 01N Pr Ims Wftlons may NOT b used. Vi 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 21J1 /ZS9-/1J4 FORD MOTOR CREDIT COMPANY Plaintiff, V. GERALD N SNELL Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-1175 PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Kindly reinstate the attached Complaint originally filed with the Court on 03/01/2006. MAURICE & NEEDLEMAN, P.C. BY: THOMAS INCZYK, ESQ. Attorney for Plaintiff Date: April 13, 2006 DATED: IN THE COURT OF COMMON PLEAS Liza B Weyandt Plaintiff OF CUMBERLAND COUNTY STATE OF PENNA. No. 06-1 1 75 VERSUS Barry N Weyandt Defendant DECREE IN DIVORCE AND NOW, 7 IT IS ORDERED AND DECREED THAT Liza B Weyandt , PLAINTIFF, AND Barry N Weyandt ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY THE COURT: -- - 'w\ ?l 2!!?lk- ATTEST: I J. ? PROTHONOTARY - '00? '-?Yg l7c7-6,4 Irril * 4V -7op -4-, MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR Plaintiff COMPANY COURT OF V. GERALD N SNELL Defendant(s) COMMON PLEAS CASE NO. 06-1175 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, GERALD N SNELL in the amount as follows: Principal Amount $ 3304.20 Interest to Date $ 266.72 Costs $ 134.97 Attorneys Fees $ 0.00 TOTAL $ 3705.89 MAURICE &.EEDLEMAN. P.C. BY: IHUMAS LVMINCZYK, ESQ. Attorney for Plaintiff MAURICE & NEEDLEMAN, P.C. Attorneys for Plaintiff BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF Plaintiff COMMON PLEAS V. CASE NO. 06-1175 GERALD N SNELL Defendant(s) 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 he/she represents the Plaintiff in the above entitled case and that Defendant, GERALD N SNELL, 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. /1?x i , P.C. BY: ESQ. Attorney for Plaintiff SWORN TO SUBSCRIBED beforWe this y o ,200 nC?? rc KYMBERLVL pacERA A NpTAAy pUBLIC OF NFIA, JERSEY My cimrrd6sion Expires 1 1 /0 112009 Suite 935, One Penn Center 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 tal. 215.665.1133 fax 215.563.8970 www.mntewpc.com Donald S. Maurice Member NJ Bar Board Cedlfed Creditors' Rghts Law American Board of Cer68cation June 14, 2006 VIA CERTIFIED & REGULAR MAIL GERALD N SNELL 109 IRON STONE RD NEW CUMBERLAND, PA 17070 Our File No. 2966 Joann Needleman RE: FORD MOTOR CREDIT COMPANY v. GERALD N Member PA d NJ Bar SNELL Thomas R. Dominczyk CUMBERLAND COUNTY COURT OF COMMON Member NJ 8 PA Bar PLEAS, CASE NO. 06-1175 Dear GERALD N SNELL: ARTBCtE NUMBER 7155 5474 41011 3665 4167 ARTICLE ADDRESS TO: Gerald N. Snell 109 Ironstone Rd New Cumberland PA 17070-2708 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 05/19/2006. 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. FEES Postage per piece $0.39 Certified Fee Return Receipt Fee 2.40 t.ss TTEMPT TO COLLECT A [ BTAINED WILL BE USED Total Postage a Fears, $4.64 IS A DEBT COLLECTOR Postmark Here 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 Plaintiff V. CREDIT COMPANY GERALD N SNELL CUMBERLAND C COMMON PLEAS CASE NO. 06-1175 COURT OF IMPORTANT NOTICE TO: GERALD N SNELL DATE: June 14, 2006 109 IRON STONE RD NEW CUMBERLAND, PA 17070 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 JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 BARASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 P.C. BY THOMAS DOICINCZYK, ESQ Attorney for PII4ptiff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF Plaintiff COMMON PLEAS V. I CASE NO. 06-1175 GERALD N SNELL Defendant(s) 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: GERALD N SNELL, 109 IRON STONE RD, NEW CUMBERLAND, PA 17070 BY: .C. THOMAS L' IN ZYK, ESQ. Attorney for Plain 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 CREDIT COMPANY Plaintiff V. GERALD N SNELL Defendant(s) COUNTY COURT OF COMMON PLEAS CASE NO. 06-1175 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 06/14/2006 to Defendant, GERALD N SNELL, 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 06/14/2006, a copy of the receipt for certified mailing to the Defendant and affidavits of service of said notice are all attached hereto. BY: THOMAS DON"CZYK, ESQ. Attorney for Plai ff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMP Plaintiff V. GERALD N SNELL Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 06-1175 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 he/she is an attorney at law and that on 06/14/2006(date) he/she mailed a written Notice of Intention to File the Praecipe to Defendant, GERALD N SNELL, at109 IRON STONE RD, NEW CUMBERLAND, PA 17070 by certified mail, article nos. 71555474410038684167. Copies of the receipts evidencing said mailing are attached hereto. The regular mail was not returned to Counsel's office, therefore, pursuant to Pa.R.C.P. §403 (1), service has been perfected by regular mail due to the fact that the Notice has not been returned to sender within fifte 5) d &r mailing,- & NEEOLISMAN. P.C. for SWORN TO A SUBSCRIBED befor me this y of q , 2A P. uy Yn he I nW? A NOFA My Co RY? Y C. PAF?EFiA ?BLIG"NEW dERSE'Y slon Expires 11/01/2009 ESQ. MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff V. GERALD N SNELL Defendant(s) CUMBERLAND C COMMON PLEAS COURT OF CASE NO. 06-1175 () Notice is hereby given that a judgment in the above-capti ned matter has been entered against you in the amount of $3705.89 on aW(o O A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. n Protho Cler 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) c ?. °` -,;? ?' ? ? ft r='?' ?? ii V :?: ??.? ?j c? Z ? ,: ? ? ?N ? `? ?'- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-01175 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS SNELL GERALD N R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: SNELL GERALD N but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On May 26th , 2006 , this office was in receipt of the attached return from YORK Sheriff's Costs: So ans s: ; Docketing 18.00 Out of County 9.00 Surcharge 10.00 mas Kline Dep York County 41.69 S riff of Cumberland County Postage .78 79.47 G 05/26/2006 MAURICE & NEEDLEMAN Sworn and subscribe to before me this day of A. D. COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST.,YORK, PA 17401 SERVICE CALL (717) 771-9601 7 ' SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LIE 1 THRU 12 DO NOT DETACH ANY COPES 1 Fond Motor Credit Company 3. DEFENDANT/S/ Gerald N. Snell 2 COURT NUMBER 1 TYPE OF WRIT OR CO CT j TA Notice and Complaint SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD Gerald N. Snell 6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO. CITY, BORO. TWP. STATE AND ZIP CODE) AT 109 Iron Stone Road New Cumberland, PA 17070 7 INDICATE SERVICE 0 PERSONAL U PERSON IN CHARGE U DEPUTIZE &MTQVMSnd a 1ST CLASS MAIL U POSTED J OTHER NOW May 5 20 06 I, SHERIFF OF VIM COUNTY, PA_ , do hereby deputize the sheriff of York COUNTY to execute make return f according to law. This deputization being made at the request and risk of the plaintiff., Lw? SHERIFF OF COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING CLinber an OUT OF COUNTY Please mail return of service to Cumberland County Sheriff. Thank you. ADVANCE FEE PAID BY ATTY. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - 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, after notifying person of levy or attachment. without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURTHOMAS R. D 0 M I N C Z Y K , E rTELEPHONE NUMBER 11 DATE FILED 935 ONE PENN CENTER,1618 JFK BLVD., PHILA PA 19103 15-789-7151 15/4/2006 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be marled) CUMBERLAND CO. SHERIFF S'P'ACE BELOW FOR USE OF THE SHEIIFF - DO NOT WRITE BELOW THIS UM 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 ExpirationlHeahng Date j or corrlplaint as indlKsted above. 15/8/2006 16/3/2006 16. HOW SERVED: PERSONAL RESIDENCE POSTED( ) POE( ) SHERIFF'S OFFICE ( j OTHER( j SEE REMARKS BELOW 17. 0 I hereby certify and return a NOT FOUND because 1 am unable to locate the individual, company, etc. named above. (See remarks below.) 18. AND 7TOFINO DUAL ED I LIST ADDRESS E IF NAT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20 Time of S ice 21. ATTEMPTS Date Time Milt's Int. Date Time Miles Int Date Time Miles Int Date Time Miles Int. Date Time Miles Int Dale Time Miles Int. 22. 23. Advance Costs osts 24 Service 25 N/F 26. Mileage 27 Postage 28. Sub Total 29. Pound 30 Notary 31 Surchg. 32. Tot. Costs 33 Costs Due eland h eck No J 100.00 C 1 K/ 1 (fJ J W 1 91 •, -'?T13 . e? ? ??ocCJ U. Foreign County Costs 35. Advance Costs 36 Service Costs 37 Notary Cert. 38. Mieage/PostagrlNot Found 39. Total Costs 40. Costs Due or Refund 41. AFFIRMED and subscribed llo beef this M 44. S p lat / y 17 45 PATE/ j 42- day of i Ni C1VL e S 46. Signature of Y 47 GATE NOTARIAL SEAL LISA L. BOWMAN, NOTARY PUBLIC County Sheriff WILLIAM M HOSE, SHERIFF V1j, 5/23/06 _ CITY OF YORK, YORK COUNTY 48. Signature of Faregn 49 DATE MY COMMISSION EXPIRES AUG. 12. 2009 County Sheriff 50 1 ACKN RETURN SIG NATURE 51 DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE `-cuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriffs Office i CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Caption: ( ) Other Ford Motor Credit Company vs. ( ) Confessed Judgment File No. 06-1175 4 Amount Due 3705.89 # Interest 5/19/06 $112.70 Atty's Comm Commerce Bank Garnishee DO 11J0_1ott? G(V& Costs 4e I I cci tme ) P4 TO THE PROTHONOTARY OF THE SAID COURT: Gerald N. Snell Defendant 16 G IPM 5'Ww -e_ ?-> C?- & fiew Cumber tGnoe 1'R'4 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 County, for debt, interest and costs, upon the following described property of the defendant(s) any and all accounts o in the name of the Defendant SS# xxx-xx-2437 a PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff ofcumberland 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) GARNISHEE-- COMMERCE BAN - Commerce Bank and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). 0 (indicate) Index this writ against the gamishee(s) as a lis defendant(s) described in the attached exhibit. Date Signature: Print Name- Address: Attorney for: Telephone: estate of the 5 ONE PENN CENTER Philadelphia, PA 19103 Plaintiff 215 789 7154 Supreme Court ID No.: 74246 (over) . 1,,, vi ,,,e? LjR[ Z `..? • w V t Ln } ?"j WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1175 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s) From GERALD N. SNELL, 109 IRONSTONE RD., NEW CUMBERLAMD, PA (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 COMMERCE BANK, 20 NOBLE BLVD., STE 1, CARLISLE, PA - ANY AND ALL ACCOUNTS IN THE NAME OF THE DEFENDANT SS# XXX-XX-2437 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 $3705.89 Interest 5/19/06 - $112.70 Atty's Comm % Atty Paid $161.97 Plaintiff Paid Date: MARCH 5, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs A"Zi... k.1" ;e ?-.. C s R. Long, P Mota By: Deputy REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 Supreme Court ID No. 74246 . FORD MOTOR CREDIT COMPANY Plaintiff, V. GERALD N SNELL Defendant(s). Commerce Bank CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-1175 Anw', 40 INTERROGATORIES IN ATTACHMENT TO: COMMERCE BANK You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default judgment against you. At the time you were served with Plaintiffs writ of execution, or at any subsequent time, did you owe the defendant (SS#: xxx-xx-2437) any money or were you liable to defendant on any negotiation or other written instrument, or did the defendant claim that you owe him/her any money or were liable to him/her for any reason? If your answer is in the affirmative, please advise the amount of money you owe the Defendant, or the amount you are liable to the Defendant. Defendant had account 536141914 with a balance of $2.09 at time served. The account is held individually. 2. At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? See answer to question 1. 3. At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? See answer to question 1. Op 4. At the time you were served or any subsequent time, did you hold as fiduciary any property in which defendant had an interest? No 5. At any time before or after you were served, did the defendant transfer or delivery any property to you or to any person or place pursuant to your direction or consent, and if so what was the consideration therefor? Defendant made deposits into the above referenced account in the ordinary course prior to service, none of which were at the direction of CmRmerce Bank. 6. At any time after you were served, did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? No 7. At the time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax or other accounts or deposits in which defendant has an interest? If the answer is in the affirmative, please advise the amount of defendant's interest thereto at the time of the service of the writ. No Commerce Bank 3801 Paxton Street Harrisbur , PA 17111 71 412-6134 Date r" C7 N a v mE A E„ ..o :9 cry ` t ? rn t? r Lret MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (11)) /Z59 /1J1 FORD MOTOR CREDIT COMPANY Plaintiff, V. GERALD N SNELL Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-1175 PRAECIPE TO DISSOLVE/WITHDRAW GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve/withdraw garnishment upon Commerce Bank forthwith. Date: April 2, 2007 Respectfully Submitted, MAURICE & NEEDLEMAN, P.C. Cl? A d 0 d r' C_-1 ..'.? ej, SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-01175 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS SNELL GERALD N And now JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0010:20 Hours, on the 15th day of March , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT SNELL GERALD N hands, possession, or control of the within named Garnishee COMMERCE BANK 20 NOBLE BLVD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to MAUREEN ROSADO (HEAD TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . , in the true and made Sheriff's Costs: So answer Docketing .00 Service .00C je?04,00-. Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 00 ? 31a 3/01 Q- 03/15/2007 Sworn and Subscribed to before me this day of A.D By eput Sheriff i 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 15) 789-'/1-')4 FORD MOTOR CREDIT COMPANY Plaintiff, V. GERALD N SNELL Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-1175 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, FORD MOTOR CREDIT COMPANY, 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. Date: August 30, 2007 July 19, 2007 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.mnlowpc.com Donald S. Maurice Member NJ Bar Board Certified Creditors' Rights Low American Board of Certification Joann Needleman Member PA & NJ Bar Thomas R. Dominczyk Member NJ, NY & PA Bar New Jersey Office MAURICE &NEEDLEMAN, P.C . 250 Route 28 West Suite 203 Bridgewater, NJ 08807 tel. 908.575.0220 fax 908.575.0632 GERALD N SNELL 109 IRON STONE RD NEW CUMBERLAND, PA 17070 RE: FORD MOTOR CREDIT COMPANY v. GERALD N SNELL CUMBERLAND COUNTY COURT OF COMMON PLEAS 06- 1175 Dear Ms Snell: Enclosed please find Notice pursuant to Pa.R.C.P. §4009.24 advising you of Plaintiff s intention to serve subpoena upon Bank of America. A copy of the subpoena is attached and which will have the Prothonotary's seal upon service to Bank of America. Thank you for your attention to this matter. Very Truly Yours, MAURICE & NEEDLEMAN, P.C. Enc. r 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 FORD MOTOR CREDIT COMPANY Plaintiff, V. GERALD N SNELL Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-1175 NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff, FORD MOTOR CREDIT COMPANY, 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. Date: July 19, 2007 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . CQ rV1o+v-r Cry 4 C' m p Cinj . V File No. o to 1) -7-S7 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: bQ A haw-r 1 'co (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: CIPI CAnCQ A C -t o-n Gt?SUQ LE qn'? s s 0 /14 - 0 - Q4- - 1 h CLd vzc cr?c't ?i? o 1A -Ccrfi o? a 4?S f " ??rr?nt" S{icf?s .6z?? l?s?+ (Address) 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: Grpr'r 4, S cl/ ADDLES S : S 1 `54 bj tacl e- ip It TELEPHONE: t S `7 -7tZ-cf SUPREME COURT ID # 7. (0 ATTORNEY FOR: Lf- Date:- 961 of he Court BY THE COURT: 114, It, j?s ?. Prothonotary, Civil Divisioij Deputy C^-4 tai ..,,,? j :_? _?., j-? " --?-- i .3 }.- _,i. ? .z= ?- ? =? `+`t - c:.; _??' ?'r .'? .. . ? «.t .?' '?? Y . ., , .++ 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1175 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s) From GERALD N. SNELL, 109 IRONSTONE RD., NEW CUMBERLAMD, PA (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 COMMERCE BANK, 20 NOBLE BLVD., STE 1, CARLISLE, PA - ANY AND ALL ACCOUNTS IN THE NAME OF THE DEFENDANT SS# XXX-XX-2437 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 $3705.89 Interest 5/19/06 - $112.70 Atty's Comm % Atty Paid $161.97 Plaintiff Paid Date: MARCH 5, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs ono Curfis R. Loll? By: Deputy REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 Supreme Court ID No. 74246 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs 84.97 Docketing 18.00 65.03 Poundage 1.67 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 10/24/07 Mileage 4.80 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 84.97 v, / 03/o -7 So Answers, R. Thomas Kline, Sheriff w / BY V- s/ q E :Z d b- ON I OOZ 44 G10(1 , (2 ?b 14 -? c