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Home My WebLink About06-2580ARBITRATION 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. DENNIS L GLESSNER 22 Spring Dr Shippensburg, Pa 17257 DIANE GLESSNER 22 Spring Dr Shippensburg, Pa 17257 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you most take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court yaw defenses or objections W the claims set forth against you You are warned that if you fail W do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. Defendant(s). Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. Q1.--d&M 14E CIVIL ACTION COMPLAINT AVISO Le han demandado a usted an la cone. Si usted quiere defenderse de estas dene ndas expuesras en las pagms siguientes, usted tiene veinte (20) dias de pluo at partir de In fecha de Is demands y B notficacion. Hare falm asentar una comparencit escrit , o en persona o con an abogado y entregar a la carte an forma escrita sus defenses o sus objeciones a las demandas en contra de an persona. Sea avisado que si usted no se defiende, Is cone tomara medidas y puede continuar In demanda an contra says sin previo aviso 0 notification. Adams, la come puede decidir a favor del demandante y requiere que usted cumpla con Wdas has provisions de esta demands. Usted puede perder dinero o sus propiedades a otms derechos impartantes psra usted. 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 SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LLEVE ESTA DEMANDA A UN ABOGADOIMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SURCIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SEPUEDE CONSEGUIR ASISTENCIA LEGAL, CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 ARBITRATION MATTER ASSESSMENT OF DAMAGES HEARING NOT REQUIRED Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY P.O. Box 6508 Mesa, Az 85216-6508 CUMBERLAND C COMMON PLEAS Case No. 06-.4.S8b &.;j 1'- T Plaintiff, V. DENNIS L GLESSNER 22 Spring Dr Shippensburg, Pa 17257 DIANE GLESSNER 22 Spring Dr Shippensburg, Pa 17257 Defendant(s). 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, Dennis L Glessner, is an individual who resides at 22 Spring Dr Shippensburg, Pa 17257. 3. Defendant, Diane Glessner, is an individual who resides at 22 Spring Dr Shippensburg, Pa 17257. 4. 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. 5. On or about September 23, 2003, the Defendant(s) entered into a written Motor Vehicle Retail installment Contract, (hereinafter referred to as the "Contract'), for the purpose of obtaining financing in the amount of $21,367.48 at an annual percentage rate of 13.990%, in order to purchase a certain motor vehicle, 2003 Ford Ranger more particularly described in the Contract (hereinafter referred to as the "Vehicle"). A copy of the Contract is attached and marked as Exhibit A. 6. Pursuant to the Contract, Defendant(s) was required to make monthly payments in the amount of $497.01 for a period of 60 months until the loan was paid in full all as is more fully set forth in the Contract. 7. Defendant(s) made monthly payments until September 26, 2005, but has failed to make any further payments thereafter, and are therefore in default of the Contract. 8. 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. 9. 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 $12900.00, however a balance of $5125.58 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. 10. Pursuant to the terms of the contract, Defendant is required to pay all amounts due and owing, including any balance that may remain after the sale of the vehicle, and the Defendant failed to do so, thereby in default of the Contract. 11. In addition to the foregoing, there is interest due and owing on the deficiency balance which at this time amounts to $166.99 and which will continue to accrue. 12. The total amount due and owing at the time of the filing of this complaint is $5292.57. WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant(s), in the amount of $5292.57, 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. r' THOMAS R. DL1MCZYK, ESQUIRE Attorney for Plain ' f 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 unsworn falsification to authorities. BI JIRE DATED: April 6, 2006 L O M .... ,_.._._..._ ......... ....... ._...._..... ........... ._ TMm F-Ity R.em A..IrNa 1. cr.ub_.._......-r :..:, TrrMlrl ? I? ?.a' n 1 ?' rrw.F ov.WS weFgF e. OnpdeN.N. N GM Nk.11 .. MgMb p M wrr M4.Ir (PMI.r eM' M r.WNq. YMIM N IMM NnN T.InwrNq CsNINMN b CMM 4NdwnnN (Iw Mm alam6wQ.._.._._..__.. CFCe inN1Yw %nr tMn N arArr,O.?' t- MwCNAV _ .? --R?"- RMn _NaeY IEgirMrll l--PM- TO TeN CmeYN In bnwe' l e'0C lelbYa.llw In Cpn rnple""'?Rfi) . e_?tby... r.l?NN 90n.0Y eY.ll N An VM Whe NINm - r+lleee. vvvN me" VwrpwrY WN11.---'gyp=ja?pf-., I.NUI Ryy10 13 Pmpr m No. OUElTCNST IF PLSASE CALL US AT T?M.ro,E a ylW N A wMr.bWtllLaen _.?.?.- N111 Ford Molcr Credit Compe.ry Prolerred Payment Plan Enrollment Mill orlatlon ® wr. fir..... C F..'?.. r. `w r '•??Y.?.5 - ?.: rrY W.rF'.w ?? YFYir?Frr?M sWYUrlr YMrLLrYanoMWWnYr. ' r• wYrw?MV T.! ?w rY..n?rY+F.r.lr F. r. r+ 1. ?M FWY M.fr.uF??rwOwYYwF.. ?wr??Yr FwFF. .r• tiw •r? wrw rY.YF ??.? r ipi .w.ew r61Y aO I.F.r ry?.OYn?MYYrY.w Yr.Nrw NMWF Yr YY?Y.YYFI. ry..OFrM NOT TO OTHER& Cre84Ee._Iw_?__ i"w meyr.C(e) SISNIa! Owe ?OlNUUey e?iNn?um? INUreC Nre OMx N NusnNT rNUIN Crg1 YM Np CM OIdNr IrMw w bblwlNwrNpt TM MN /.w?i wwYF ? 4. w4.wy?Fx 11 IN N.:rN;wa?Fw- \: b e.r N M eYelY• MrMI .FUI1N mn. 0Cr?^-?? OONCI.MIYN.I 0 F 1FRCPitlMMtl4bwICVM.w rY eMl'r.e. O TF.9NFN el UN co~ you sign. ^PRN^ Fad Malin Direst CMPEV P.O. Box 3076 COLUMBIA, MD 210964076 OW)STroTm 403Nnoa2aoaW DIANE GLESSNER 22 SPRING DR SHIPPENSBURG PA 17257 DabaRepwnsiw 11-30-20M Date of Ndli Deft of COMrad 1242-2006 09-232003 Amount Number: (G5467274 0 DENNIS L. GLESSNER Cob DIANE GLESSNER DESCRIPTION OF PROPERTY YW New, Now 20IX1 FORD ? l1W VahlGe N1Mi6cetlon Number: 1FT2R46H13PB33003 Motel Body RANGR 4%4 NOTICE OF OUR PLAN TO SELL PROPERTY We nave your property dnaibed above because you bake promtns In ow agraamerrt. MX PRIVATE SALE: We will sail me proprty described fib" 91 prlvste sale somelbre after 76 days nom Ie Date a Notbe drown above unless redeemed by you prior to such "le. [] PUBLIC SALE: We wil an the propMy tlawribed above atPubeo sale btiro NO" bidder on the date WON (W any 1*a ffeM deal). The sale Wes be haw as follow Dmwsan Tk"Olsats PMe of use You may altslg the sale and bring biddles a you warl. The money that we get from the sale (after paying our costs, including reasonable ahomey's fees and legal expenses if permitted by law) will reduce the amount you owe. If We get less money than you owe, you wgl still owe us the difference, it we plot nygre money than YOU owe, You will get the e)Q15 money, unlestrwe must pay it to someone else. ' You can get the property back at any time before we sell it by paying us the full amount you owe (not just the past due payments), including our expenses. See How To Got Your Property Back for an itemization of amount owing. To learn the exact amount you must pay, call us at the telephone number above. If you need more information about the Sale call us at the telephone number above, or write us at the address above. If you want us to explain to you In writing how we have figured the amount that you owe us, you may call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money under your agreement: 1) The buyer and any cobuyer named above; 2) Any deaterforiginal creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. OF The property is presently stored at: BEN RECOVERY BEN REWWRY 0TEWPA____ HOW TO GET YOUR PROPERTY BACK To get your Properly bwk, pry w this amount by cernnn check a money ardar hsfae be rabble is soli. Unpaid Balance $ 18,308.34 Plus Costs: BFPO rile-- _ { . 20DpD It- Plus LW Charges $ 2925 Lase Firembi Charge Rebels $ Len Insursnce Premium Rehaaa a TOTAL $ 19,626.00 (Plus eopenxe m umed it defadl at be time m repossession aacesdad is aye and less relwa nested after the dote of We robot.) Your property wont be sold until 16 a ys after be ate of this Mike at me EARUEST. ARW Met you esn en0 geta peek anytime Mae t'S aolually sold. If You a, "It here no farina olalm on a. But the longer YOU vas. the mono casts (Inobudaq Weire) you may here to pay. If you have am/ question about this, plena Call u. The property has been (awe be) reMmedto: (OnlerlariBYW aeditor) Urger our agreement with your dealehagnai credbor, ee dealeMoriginal creditor is to sell be property and Pay you any money lee over. R you awe arrawy after the sale, you will pay 9 to me aeMr(odgmet ruedkm. ? PERSONAL PROPERTY'. Any personal properly IoW In Ie v w may W reeleini by you within the nea 60 days or. in socadance with erase law, by correcting thre strips. Thereafter, the peracnai property sraN be bapoaad of aocadingly. ? CmdOa has nagned Io a qualified a"m-dany, (at Ewohartl LLC) Ire rights (but not as obryaibne) iwn'"Paid to be Asia of rich vehicle "re"d above PAYMENTS: An payments to w moral be by carmed cMck or money orar. MILEAGE DISCLOSURE: If you ors aware aisle ma maeapa faMCted on sat whlcle'a atlonlWr le nW accwrats to arcy reason, please uv'tect ua so Iher we cer, accwafely raw Me vehicle'. mileage. INSURANCE RIGHTS: II YW don't weM to Bet Your Preperty Wek, cW tea Inaruanea company a 6ro aaledanglnal eretlad ts nlen sure IM eery Inaurenee tin been c mcerisd. You hale a right to get credit for all Premium retina. JESSICA A. SNYDER Arne IItMA?sn oa Prwwawsaua mw noTa wa. CUSTOMERICUSTOMER FILE RqM P Us ... PRI Ford Motor Credit Consairly P.O. am We COLUMBIA, MD21045-6076 (ea) 6"4m P rJ8830W38 DENNIS L. GLESSNER 22 SPRING DR SHIPPENSBURG PA 17257 wsbn 11-362005 DWO INdim o,ledNOllca DalerContract 12024006 0623,= A0ern1 Nlmbw: OdtH6727A Buyer DENNISL. MESSNER CQWYW DIANE GLESSNER DESCRIPTION OF PROPERTY Yaw MW 1003 FORD Q Blew ? used Vehicle lit MMmtbn Nunfbtr IFTZR45E13PB330a3 Ma W RANGR Body JX4 NOTICE OF OUR PLAN TO SELL PROPERTY We have your property described above becausa you broke prrrdsas In our agreement. ?x PRIVATE SALE: We w,U are the property daacdbed above M private sale somMNne after 16 days from the Date of Notice Mown above unless redeemed by you prior to such sale. ? PUBLIC SALE: We will sail the pop" careaLW above at public seb to the highest deder on the date below (or my.dlourrmlPnt date). The aW veil be held sa fdbwa: parental TMs of gale Phacs of SW You nay wend the sap and ping bidders N you ward. 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 legs money Ulan you owe, you will still we us trip di (emote. 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 property beck 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 team the exact amount you must pay, Cell us at the telephone number above. If you need more information about the sale call Us at the telephone number above, or write us at the address above. If you want us to explain to you in writing how we have figured the amount that you owe us, you may call us at the telephone number above, or write us at the address above and request a written explanation. We are sending this notice to the following people who have an interest in the property described above or who owe money under your agreement: 1) The buyer and any cobuyer named above; 2) Any dealer/original creditor named below; 3) If there are other people, they are named on an attachment sent with this notice. The property is presently stored at: BEN RECOVERY BEN RMWERV EPfERSW HOW TO GET YOUR PROPERTY BACK To get your property back, pay us this amount by cemaae check or moray crow before the vstpcls is add. Unpaid Balance $ 18,300.34 Plus Costa: Reno Eapenwa $ 2XLD . E Plus LW Charges S 2x.20 Lea Finance Charge Rsbse a Lwa lnandencs Prembm Rebut Ill- TOTAL $ 18.625.60 (Plus IMPeneea incurred If defaua st the ikne of fepo sesabn mcestled If days and less rebrte receNwl •eer the dW rmis notice.) Your property won't be sold and 16 days after the dW of this rolbe at the EARLIEST. After eat you can 01 get N back say Ume before 1's actually sold. If you do, well hive no further clmn on N. But the longer you watt, the mon coats (induNng rtpein) you may have to pay. It you he" any questions about Ws, please call us. ? The property Ms been (orw11 w) returned to Under rg ag'"ens wish your de•krlrIDVW reritor, be tie lmoni kwl creditor is ta ell the (dsww(rlgkw Crater) after the sale, you wsl g properly and pay you any mor" left over. If you owe money pay h to me dsWr/Mplnel creditor ? PERSONALPROPERTY: Any personal property found intro vetNeb may Wnclalma, byyoowithinme real 60 days r, in ecmrdancewAh sele hex, by contacting this office. ThenNer, the Personal popery shall W eapoetd of accordingly. ? DrMNr taw sssgnetl to Ma qu4Netl In[errtwdiery (OI Evaheige, LLCI Na dgMS (rid net Ns obligalimn) wed respeol to,w eW N wdl vMick feted above, PAYMENTS: All paynn res to us must w by -ml check r money order. MILFAGE DISCLOSURE: ]?You art aware that the mileage released! on Me vehlole'a odomater is not accuraM for wry reason, please contact us Were" can acountey repot the vehicle'. massge, INSURANCE RIGHTS: If you don't went to g4 your property back, call the Insurance oompury or the dwlerlorigisal creditor to mean sure that any Insurance her been canceled. You haw a right to get credit for YI premium refunds. JESSICA A. SNYDER nuB'IM47.len ozmwuneenwoa Ire,, noT on CUSTOMERICUSTOMER FILE Rlnm In Us a. Ld a1?v.a.watwNa: uremlw. o ? ~ ? "?^••nnrror.woro ,P„MiiiO,r y,',tt„? a 0 wr t00o w u1201I/2 7 7005 64 7005 2570 0000 9993 64NO 2S70 0000 9993 2697 ---DWJE GLESSNER 2 THOMAS M. KELLY 22 SPRING DR 94 NEW STREET SHIPPENSSUR0 PA 17257 POTTSVILLE PA 17901 ----- --------- U120U20552398 7005 2570 0000 - ur2JV20SS2a0? 7005 2570 0000 4993 BA-025187081 9993 --- JJ-034918598 2703 w-CYNTHIAA. SCHUETRUM --` - NICOLAS LEBRON 413 TURKEY RUN 1060 STERLING PL SHENANDOAH PA 17978 ---- ------- - LANCASTER PA 17803 U1201120562M9 BA-024246375 MARK J. WILDE 52 CENTER AVE - KINGSTON PA 18704 _ U1201120662400 7. BR-031219254 STEVE B. WORK 112 CENTRE LINE AVENUE WILLIAMSPORT PA 17701 ' B. 2727 M Prl-W Act$Mrt ntm r- DEC 022005 •wnrq Mm'.ra6Ytlr ClrG /pam?pa MlMti 38120 Amrhein A4 P? " ary: W i M .. . .. opind"60 on a, l 48 E3 pgji?wkl •u+rw.en ara •••+r/rfta.a ox a`?&>ymc rur 'r'ely . r 1. U1201T20552985 c w BM038987123 MARY STEUATC 7005 2570 0000 9993 2574 1801 EDOELY RD . - 201/20562398 1 2. LEVITTOWN PA 1M15 J-035057274 •?? • ------- DENWSL OLESSNER -._._22 SPRING DR SHIPPENSBURG PA 11257 3. Umml)552386 7005 2570 0000 4993 2581 BA-029604112 VINCENT FARRELL 1.01201720562390 2161 BEAR CREEK BLVD ------------ JJ-0St918599 ??. 4. WILKESSARRE PA 16702 ANGEUNA MALDONADO 10600 0STER 8TERUNG PLACE LANCASTER PA 17603 U120v20552387 7005 BR-031219261 2570 0000 9993 2598 _-- OEBORAN A. WORK 112 CENTRE UNE AVE _ WILUAMSPORT PA 17701 ----- 7. U1201120552388 EB-032224098 7005 2570 0000 9993 2604 & JOHN M. ----- 1200 W RIVER RD 050 SPARTAWI54856 --'- DEC 0 2 .20 .r Ge fem? 787f, 8" POvcry Act It =wd w Rev*M = P?Wmm P?wfay cwrr. r.n•e...... u. __a-..?._._ _ Ford Motor Credit Company PO BOX 3076 COLUMBIA MO 21045$076 800 6770730 DATE: 2006-01-11 PMR0100000078 DIANE GLESSNER 22 SPRING DR SHIPPENSBURG PA 17257 DENNIS L. GLESSNER 22 SPRING DR SHIPPENSBURG PA 17257 STATEMENT OF SALE Account Number. 035457274 The following property has been sold. Year Make Model Vehicle identification Number: 2003 FORD RANOR 1FTZR45E13PB33063 Balance owing on your contrail (1) $ 18,425.60 Deduct: Finance Charge Rebate (2) $ 0.00 Balance less Finance Charge Rebate (1 - 2) (3) $ 18.425.60 Deduct: gross proceeds of the sale (4) $ _12.900.00 Balance less gross proceeds of the sale (3 - 4) (5) $ 5,525.60 Add: Expenses of retaking and storing, and (6) $ 381 00 any attorneys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate (7) $ 0.00 (8) $ 781.02 Other: (9) $ 5125.56 Deficiency" (10) s N/A Surplus' 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 FFNA119W 01ro Pr use tans may NOTb us , • Ford Motor Credit Company PO BOX 3076 COLUMBIA MD 21046-6076 800 6770730 DATE: 2008-01-11 P03RO1000DW77 DENNIS L. GLESSNER 22 SPRING DR SHIPPENSBURG PA 17257 DIANE GLESSNER 22 SPRING DR SHIPPENSBURG PA 17257 STATEMENT OF SALE Account Number: 035457274 The following property has been sold. Year Make Model 2003 FORD RANGR Balance owing on your contract Vehicle Identification Number: 1FTZR45E13P1333063 Deduct: Finance Charge Rebate Balance less Finance Charge Rebate (1 - 2) Deduct: gross proceeds of the sale Balance less gross proceeds of the sale (3 - 4) Add: Expenses of retaking and storing, and any aftomeys' fees allowed by law, and expenses of reconditioning and selling. Deduct: Insurance Premium Rebate Other: (1) $ 18,425.60 (3) $ 18 425.80 (5) $ 5 525.60 (9) $ 5125.58 Deficiency" (10) $ NIA Surplus' The Surplus/Deficiency will change based on monies received by us (credits) or additional allowed expenses $ interest added to your account (debits). _ Surplus' or Deficiency" If the sale resulted in a surplus, a refund for the difference will be mailed to you. •` If the sale resulted in a deficiency, you should immediately remit the amount shown on line 9 to the address for payments shown below. For additional information call or write: Mall 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 (2) $ 0.00 (4) $ , 12,900.00 (6) $ 381,00 (7) $ 0.00 (8) $ 781.02 FFNA119W 01N4 Pre l C toms may NOT W uwi. AA? vi 4Q. c z? ?G N -c t cn ro N O ?D ro QGj 8 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. CASE NO. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s) 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, DENNIS L GLESSNER AND DIANE GLESSNER in the amount as follows: Principal Amount $ 5125.58 Interest to Date $ 387.02 Costs $ 117.98 Attorneys Fees $ 0.00 TOTAL $ 5630.59 , P.C. BY: Attorney for ESQ. 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. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER 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, DENNIS L GLESSNER, 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 and the amendments thereto. MA & ED P.C. BY: T MAS D YK, ES Q. Attorney for Plaintiff SWORN TO UBSCRIBED beforg}ne this1: o (• u i 2 KYM RLYL.PAPERA A NOTARY PUBLIC OF NEW JERSEY My Commission Expires 11/01/2009 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. DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s) COMMON PLEAS CASE NO. 06-2580 COURT OF AFFIDAVIT OF MAIL SERVICE STATE OF NEW JERSEY COUNTY OF SOMERSET SS. THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law, deposes and says that he/she is an attorney at law and that on 06/02/2006(date) he/she mailed a written Notice of Intention to File the Praecipe to Defendant, DIANE GLESSNER, at22 SPRING DR, SHIPPENSBURG, PA 17257 by certified mail, article nos 71555474410038683627. Copies of the receipts evidencing said mailing are attached hereto. A copy of the signed green card hereto as well. SWORN TO ,SUBSCRIBED befor me this ay ?yf Mp , 2006. tP p KYMYLPA BRA A NOTAAY PUBLIC OF NEW JERSEY My Commission E)Vres 11!01/2009 THOMAS DOWNC: Attorney for Plaintiff attached P.C. 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. DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s) CUMBERLAND C COMMON PLEAS CASE NO. 06-2580 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 06/02/2006 to Defendant, DIANE GLESSNER, 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 06/02/2006, a copy of the receipt for certified mailing to the Defendant and affidavits of service of said notice are all attached hereto. BY: THOMAS I50JNCZYK, ESQ. Attorney for Plaintiff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff V. DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 06-2580 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: DIANE GLESSNER, 22 SPRING DR, SHIPPENSBURG, PA 17257 BY: THOMAS D-OME4VZYK, 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 VIOTOR CREDIT COMPANY CUMBERLAND COUNTY Plaintiff COMMON PLEAS V. I CASE NO. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE STATE OF NEW JERSEY COUNTY OF SOMERSET SS. THOMAS DOMINCZYK, ESQUIRE, being duly sworn according to law, deposes and says that he/she represents the Plaintiff in the above entitled case and that Defendant, DIANE GLESSNER 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 there r its Allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 a e amendments thereto. MA C LE P.C. BY: HOMAS DOM CZYK, ESQ. Attorney for Plaintiff SWORN TO AN??UBSCRIBED befor e 411b 9 y of , 200L. NOTARY PUBLIC OF NEW JERSEY My Commission Expires 11/01/2009 June 2, 2006 Suite 935, One Penn Center Our File No. 3655 1617 John F. Kensd7 Blvd. Ph9edelptna, PA 19103 tel.215.815SA 133 fax 215.593.9970 VIA CERTIFIED & REGULAR MAIL www.mnlawpc.com DENNIS L GLESSNER 22 SPRING DR Donald s. Maurice Member NJ Bar SHIPPENSBURG, PA 17257 Board Certified Creditors' Rights Law American Board of Certification RE: FORD MOTOR CREDIT COMPANY v. DENNIS L Joann Needleman Member PA8NJBer GLESSNER AND DIANE GLESSNER CUMBERLAND COUNTY COURT OF COMMON Thomas R Domm4k Member NJ, NV 8 PA Bar PLEAS, CASE NO. 06-2580 Dear DENNIS L GLESSNER: 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 05/09/2006, 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. THOMAS DOMWZYK, ESQ. ARrtCI.E NA111"M 7155 5474 4100 3666 3634 ARTICLE ADDRESS TO: Dennis L. Glessner 22 Spring Dr Shippensburg PA 17257-9455 FEES Postage per piece 50.39 Certified Fee 240 85 1 EMPT TO COLLECT A Return Receipt Fee . TAINED WILL BE USED Tout Postage 6 Fees: A DEBT COLLECTOR Postmark Here 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. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER Defendant s) IMPORTANT NOTICE TO: DENNIS L GLESSNER DATE: June 2, 2006 22 SPRING DR SHIPPENSBURG, PA 17257 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 BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 P.C. THOMAS pQMINCZYK, ESQ Attomey f Plaintiff June 2, 2006 Suite 935, One Penn Carder Our File No. 3655 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215.885.1133 fax 215.563.8970 www.mnlawpo.com Donald S. Maurice Member NJ Bar Board Coddled Creditors' Rights Law American Board of Cer88oa8on Joann Needleman Member PA & NJ Bar Thomas R. Dominczyk Member NJ, NY & PA Bar Thank you for your prompt attention to this matter. ESQ. ART=E t4UMEER 7155 5474 4100 3868 3627 ARTICLE ADDRESS TO: Diane Glessner 22 Spring Dr Shippensburg PA 17257-9465 VIA CERTIFIED & REGULAR MAIL DIANE GLESSNER 22 SPRING DR SHIPPENSBURG, PA 17257 RE: FORD MOTOR CREDIT COMPANY v. DENNIS L GLESSNER AND DIANE GLESSNER CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 06-2580 Dear DIANE GLESSNER: 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 05/09/2006. Unless an answer to Plaintiffs 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 and ask for Kim Crosby. FEES Postage per piece Certified Fee Return Receipt Fee Total Postage a Feaa: Postmark Here So .3s TTEMPT TO COLLECT A 2.4o BTAINED WILL BE USED 1.85 IS A DEBT COLLECTOR 54.64 It 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. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s) IMPORTANT NOTICE TO: DIANE GLESSNER DATE: June 2, 2006 22 SPRING DR SHIPPENSBURG, PA 17257 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT 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 ELIGLE PERSONS AT A REDUCED FEE OR NO FEE: CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue, Carlisle, PA 17013 (717) 244-3166 NEEDLEMAN, P.C. Attorney 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 gOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF Plaintiff COMMON PLEAS V. I CASE NO. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER 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: DENNIS L GLESSNER, 22 SPRING DR, SHIPPENSBURG, PA 17257 BY: P.C. THOMAS DOMEICZYK, ESQ. Attorney for Plaintiff MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Thomas R. Dominczyk, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7154 Attorneys for Plaintiff FORD MOTOR CREDIT COMPANY Plaintiff V. DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 06-2580 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 06/02/2006 to Defendant, DENNIS L GLESSNER, 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 06/02/2006, a copy of the receipt for certified mailing to the Defendant and affidavits of service of said notice are all attached hereto. MAURICE & IWEDLEMADY, P.C. BY: THOMAS DONWCZYK, 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. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s) 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 06/02/2006(date) he/she mailed a written Notice of Intention to File the Praecipe to Defendant, DENNIS L GLESSNER, at22 SPRING DR, SHIPPENSBURG, PA 17257 by certified mail, article nos. 71555474410038683634. Copies of the receipts evidencing said mailing are attached hereto. A copy of the signed green card evidencing re ipt aid cling is attached hereto as well. BY: Attorney for C' U'"4 '20 P.C. SWORN TO A JUBSCRI13ED befo me this y ESQ. A NOTARY PUWC OF NEW JERSEY My Cw Nssion Expires 11/01/2009 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. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s) () Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $5630.59 on ?L 2 AM* A copy of all documents filed with the Prothonotary in support of the within judgment 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) ?, °?' ? ? ? o '' n .?h 1 Y ' ?(yi'?`? t ??""• a ? r ?' r ?-„ -n,e ? ? ?'> m? , t, -?, ?, ?? _ ? ? y, ? ? to SHERIFF'S RETURN - REGULAR 1 c CASE NO: 2006-02580 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS GLESSNER DENNIS L MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GLESSNER DENNIS L the DEFENDANT , at 1556:00 HOURS, on the 9th day of May 2006 at 22 SPRING DRIVE SHIPPENSBURG, PA 17257 by handing to DIANE GLESSNER, 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 18.48 Affidavit .00 Surcharge 10.00 .00 46.48 Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 05/10/2006 MAURICE & NEEDLEMAN By. Deputy S eriff Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2006-02580 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS GLESSNER DENNIS L MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon (!T L+CCTTVD TIT7VNTV the DEFENDANT , at 1556:00 HOURS, on the 9th day of May , 2006 at 22 SPRING DRIVE SHIPPENSBURG, PA 17257 DIANE GLESSNER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 l b'/L-t ?DI? u Sworn and subscribed to before me this day of A. D. So Answers: R. Thomas Kline 05/10/2006 MAURICE & NEEDLEMAN By: epu She ff Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ( ) Confessed Judgment ( ) Other Ford Motor Credit Company vs. 4 Amount Due 5630.59 Interest 8/14/2006 $220.29 DENNIS L GLESSNER AND DIANE Atty's Comm GLESSNER l Z ?C2. Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below. does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but If it does, it is based on the appropriate original Proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue 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) any and all accounts or property in the name of the Defendant SS# xxx-xx2651 & xxx-xx-7900 I? iW- Pb County, SLQ17 v? 7 T5c-1e? fftq14- S?- Cr-C I' C-a 12iA- 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) 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 [is pendens against real estate of the defendant(s) described in the attached exhibit. Date Signature: Print Name- ?.M1 Address: -,ft- PM-PW. rn IN03 Attorney for: PAR Telephone: File No. 06-2580 215 M 7154 Supreme Court ID No.: (over) ? „? Ul C7 d -p b , r :3 ? LV3 ` `~ rrt`fn •L7 V16`6 - -T V I Y ? ^ Q 4 ? f . ? S' . / y ? hy ? Mw ov) FORD MOTOR CREDIT COMPANY Plaintiff, V. DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-2580 WRIT OF EXECUTION NOTICE This paper is a Writ if 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. If you wish to exercise your rights, you must act promptly. Exempt Property, 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. Attached is a summary of some of the major exemptions. You should do the following promptly: (1) Fill out the attached exemption claim form and demand a prompt hearing; (2) Deliver the form or mail it to the Sheriffs Office 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. Property Belonging to Another Person. If there is property at your residence [or your bank account] that belongs to another person or that you own with another person, you should notify that person so that he/she can file a property claim or other legal papers with the Sheriffs Office to prevent his/her property from being taken or sold at Sheriffs Sale to satisfy your debt. See enclosed forms. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION FIND OUT WHERE YOU CAN GET LEGAL HELP. SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland Bar Association Lawyer Referral and Information Service 2 Liberty Ave, Carlisle, PA 717 249 3166 EXHIBIT A PLAINTIFF: FORD MOTOR CREDIT COMPANY VS DENNIS L GLESSNER AND DIANE GLESSNER Court Tenn & No.: 06-2580 CLAIM FOR EXEMPTION TO THE SHERIFF: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be [ ] (1) set aside in kind (specify property to be set aside in kind): [ ] (2) paid in cash following the sale of the property levied upon; or (b)I claim the following exemption(specify property and basis of exemption): (2) From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 exemption: [] in cash [] in kind (specify property): (b) Social Security benefits on deposit in the amount of. $ ; (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Name, Address & Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unworn falsification to authorities. Date: Defendant(s): Address: City, Zip: THIS CLAIM TO BE FILED WITH: DEFENDANT Office of the Sheriff of Philadelphia County ONE COURTHOUSE SUARE, CARLISLE PA, 717 240 6195 Note: Under paragraphs (1) and (2) of the writ a description of the specific property to be levied upon or attached may be set forth in the writ, or included in a separate direction to the Sheriff. Under paragraph (2) of the writ, if the attachment of a named garnishee is desired, his/her name should be set forth in the space provided. Under paragraph(3) of the writ, the Sheriff may, as under prior practice, add as a garnishee any person not named in this writ that may be found to be in possession of property of the defendant. See Rule 311 l(a). For limitations on power to attach tangible property, see Rule 3108(a). (b) Each court shall by local rule designate the officer, organization or person to be named in the notice. MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW (1) $300.00 statutory exemption (2) Bibles, school books, sewing machines, uniforms and equipment (3) Most wages and unemployment compensation (4) Social Security benefits (5) Certain retirement fund and accounts (6) Certain veteran and armed forces benefits (7) Certain insurance proceeds EXHIBIT "A" FORD MOTOR CREDIT COMPANY Plaintiff, V. DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s). M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-2580 INTERROGATORIES IN ATTACHMENT TO: M & T 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. 1. At the time you were served with Plaintiffs writ of execution, or at any subsequent time, did you owe the defendant (SS # xxx-xx-2651, SS# xxx-xx-7900) 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. 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? 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? . v 4. At the time you were served or any subsequent time, did you hold as fiduciary any property in which defendant had an interest? 5. At any time before or after you were served, did the defendant transfer or delivery any property to you or to any person or place pursuant to your direction or consent, and if so what was the consideration therefor? 6. At any time after you were served, did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 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. JOA EIJMAN, ESQUIRE Attorn for laintiff 935 O Penn Center Philadelphia, PA 19103 2157897154 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2580 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 DENNIS L. GLESSNER AND DIANE GLESSNER, 22 SPRING DR., SHIPPENSBURG, 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 M & T BANK, 1 W. HIGH ST., CARLISLE, PA GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $5630.59 Interest 8/14/06 - $220.29 Atty's Comm % Atty Paid $153.98 Plaintiff Paid Date: MAY 7, 2007 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs Curtis (R. Long, Proth By: REQUESTING PARTY: Name JOANN NEEDLEMAN, ESQUIRE Address: 935 ONE PENN CENTER PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-789-7154 Deputy Supreme Court ID No. f ? FORD MOTOR CREDIT COMPANY Plaintiff, V. DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s). M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-2580 MAY 2 S 200? Pes o 4V INTERROGATORIES IN ATTACHMENT TO: M & T 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. 1. At the time you were served with Plaintiff's writ of execution, or at any subsequent time, did you owe the defendant (SS # xxx-xx-2651, SS# xxx-xx-7900) any money or were you liable to defendant on any negotiation or Aer 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, M & T BANK or the amount you are liable to the Defendant. HAS NO OPEN ACCOUNTS FOR ABOVE NAMED 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? 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? 4. At the time you were served or any subsequent time , did you hold as fiduciary M & T BANK any property in which defendant had an interest? HAS NO OPEN ACCOUNTS FOR ABOVE NAMED 5. At any time before or after you were served, did the defendant transfer or delivery any property to you or to any person or place pursuant to your direction or consent, and if so what was the consideration therefor? 6. At any time after you were served, did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 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. C ? ,? Bpr1K , ESQUIRE tome Plaintiff 5 Pfie -Penn Center adelphii, PA 19103 5 789 7154 FORD MOTOR CREDIT COMPANY Plaintiff, V. DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s). M&T BANK CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-2580 MAY z ? zoo? INTERROGATORIES IN ATTACHMENT TO: M & T 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. 1. At the time you were served with Plaintiff's writ of execution, or at any subsequent time, did you owe the defendant (SS # xxx-xx-2651, SS# xxx-xx-7900) 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, . M & T BANK or the amount you are liable to the Defendant. HAS NO OPEN ACCOUNTS FOR ABOVE NAMED 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? 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? 4. At the time you were served or any subsequent time , did you hold as fiduciary M& T BANK any property in which defendant had an interest? HAS N OPEN ACCOUNTS FOR ABOVE NAMED 5. At any time before or after you were served, did the defendant transfer or delivery any property to you or to any person or place pursuant to your direction or consent, and if so what was the consideration therefor? 6. At any time after you were served, did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 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 defendan t 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. S O NK O NN DL AN ESQUIRE %3 96a Senn Center adelphia;` PA 19103 15 789 7154 V -TI 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 15) 789-7151 FORD MOTOR CREDIT COMPANY Plaintiff, V. DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-2580 PRAECIPE TO DISSOLVE/WITHDRAW GARNISHMENT TO THE PROTHONOTARY: Kindly dissolve/withdraw garnishment upon M&T Bankforthwith. Respectfully Submitted, MAURICE & NEEDL , P.C. Date: May 30, 2007 (Z? -40. O C3 C=k f'' 73 6 61) I SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-02580 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND FORD MOTOR CREDIT COMPANY VS GLESSNER DENNIS L And now RICHARD SMITH ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:20 Hours, on the 24th day of May , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT GLESSNER DENNIS L hands, possession, or control of the within named Garnishee M & T BANK 1 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to PRUDENCE SHANK (CUSTOMER SERVICE REP) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 00 ??30/0 7 v" .00 Sworn and Subscribed to before me this . in the true and made so e?? 0 R. Thomas Kline Sheriff of Cumberland County 05/24/2 day of By A.D a" % MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Attorneys for Plaintiff Identification No. 74276 BY : Charlene Taylor Identification No. 203920 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (L1J /t5y-71J4 FORD MOTOR CREDIT COMPANY CUMBERLAND COUNTY COURT OF _--_----_ _ _ _ __ - _ . COMMON PLEAS Plaintiff, V. Case No. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s). 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: December 27, 2007 k November 28, 2007 Attorneys at low 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. Mowice Member NJ Bar Board Certified (reditori Bights Low American Board of (edification Member PA & NJ Bar Thomas B. Dominc:yk Member NJ, NY & PA Bar Charlene A. Taylor Member PA Bar DENNIS L & DIANE GLESSNER 8139 MOLLY PITCHER HWY APT A SHIPPENSBURG, PA 17257 RE: FORD MOTOR CREDIT COMPANY v. DENNIS L GLESSNER AND DIANE GLESSNER CUMBERLAND COUNTY COURT OF COMMON PLEAS 06- 2580 Dear Mr/Ms GLESSNER: Enclosed please find Notice pursuant to Pa.R.C.P. §4009.24 advising you of Plaintiffs intention to serve subpoena upon Credit Acceptance. A copy of the subpoena is attached and which will have the Prothonotary's seal upon service to Credit Acceptance. Thank you for your attention to this matter. Very Truly Yours, MAURICE & 1EEDLEMAN, P.C. ?i e4leamn, Esq. or t Firm /ce 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 New Jersey Office Maurice & Needleman, P.C. Suite 2007 5 Walter E. Foran Blvd. Flemington, NJ 08822 tel. 908.231A5S0 fox 908.237.4551 MAURICE & NEEDLEMAN, P.C. By: Joann Needleman, Esq. Identification No. 74276 BY : Charlene Taylor Identification No. 203920 Suite 935, One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215} 789-7161 FORD MOTOR CREDIT COMPANY Plaintiff, Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 06-2580 DENNIS L GLESSNER AND DIANE GLESSNER Defendant(s). 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: November 28, 2007 A# COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. ??tnl S ?- Ct ?? S S h Pte- ? ?1G?1 ? (e-S? r SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: I (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: W aS oc [ 6 0- 4? - 7q&b sfuk ktad? bX1 CkCK k qtr Cne?!j L/ L/ at ' Y `ci a a V - ?''-Qkdkfxk F- C. . (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: l,a-G,'Fgm 1 ei; i Tn?rjD? S 3 &IA ?''6?N?Qr,f) C4 i !? t 6 TELEPHONE: Z "ZC Z '7 SUPREME COURT ID # -7 Ck ATTORNEY FOR: CZCA- BY THE COURT: Date:_ 11 30 0 eal f the Court lsl du.iti P. ?Zr T Prothonotary, Civil Di ion Deputy ,?-? m rv Q ? =? ? ; -=' r_;' 1 ^% . ?...I wr ? i ..`.y, `....., ....+,.?i t ??- J? <?' .?" C„rt ..S 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 85.99 Docketing 18.00 64.01 Poundage 1.69 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 03/25/08 Mileage 4.80 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 85.99 r -//1 3Jo F So Answers, R. T gmas Kline, S ff heri By 1 ?L c ;u 3L? a c. WIZII OF EYE(' I IO\ anwoa 1 I l 'ti WNILN CU?I ION\V1,\L III OI PI NN 1"i.\ .Nisi CO( ?N V ' OE Ut t)413ERLAND? t ? 06-2580 ( i \ i l ('I\'11 \C T1O\'' 1 \l? f0 Tl IE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s) From DENNIS L. GLESSNER AND DIANE GLESSNER, 22 SPRING: DR.. SHIPPENSBLRG, P,x (1) You are directed to Levy upon the property of the defendant (s)and to soli (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 1N1 &T BANK, I W. HIGH ST., CARLISLE, PA GARNISHEE(S) as lolloxvs: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnisheets) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the delendant (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 ,4 garnishee and is enjoined as above stated. Amount Due $5630.59 Interest 8/14/06 - $220.29 Any's Comm °4, Atty Paid $153.98 Plaintiff Paid Date: MAY 7, 2007 (Seal) L. l - S.50 Due Prothy $2.00 Other Costs Curtis Long, Prot tary, 'i. 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. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-2580 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 DENNIS L. GLESSNER AND DIANE GLESSNER, 9557 OLDE SCOTLAND ROAD, SHIPPENSBURG, PA 17257 (I ) 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-4 T Bayl k, I We s? ?h9 ti C4 r I? S h ??°/3 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 $5,630.59 Interest FROM AUGUST 14, 2006 - S1,861.30 Atty's Comm % Atty Paid $274.47 Plaintiff Paid Date: APRIL 5, 2012 (Seal) L. L. Due Prothy $2.25 Other Costs ;L-CL- David D. Buell, Prothonotary 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 FORD MOTOR CREDIT COMPANY I , 1335 S. Clearview Avenue I No. 06-2580 GHN41At' Mesa, AZ, 85209 I r ; ';t rts? -? PCi 2 I Plaintiff(s) I AJkIBERLA1°ID GONT'1` CIVIL ACTION' PE-wiSyLVANIA I V. I PRAECIPE FOR WRIT OF EXECUTION (Money Judgment) DENNIS L GLESSNER and DIANE GLESSNER 9557 OLDE SCOTLAND ROAD SHIPPENSBURG PA 17257 Defendant(s) TO THE PROTHONATORY: (1) Issue writ of execution in the above matter, directed to the Sheriff of CUMBERLAND County, against DENNIS L GLESSNER and DIANE GLESSNER , defendant(s) (2) and against, M & T BANK, 1 WEST HIGH ST, CARLISLE, PA 17013 garnishee. AMOUNT DUE $5,630.59 INTEREST $1,861.30 from: August 14, 2006 PLUS COSTS (3) auk%aq , 0opa y(?.YR- C 1(0.00 S. 94? till SS. Soptl a Dated: March 29, 2012 L9 t4. So 31, c5D Sa7q pa a FILE NO.: FT 110496 Andrew Sklar, squire Attorney for Plaintiff ID #65332 Sklar - Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill, New Jersey 08003 (856) 616-8710 ? a. as use ?• Ck? 18S4y pt r / IN THE r'OURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff vs. DENNIS L GLESSNER and DIANE GLESSNER Defendant :No. 06-2580 :CIVIL ACTION PRAECIPE FOR SUBSTITUTION OF COUNSEL TO THE PROTHONOTARY: ot, Kindly substitute Andrew Sklar, Esquire of the law offices of Sklar - Markind, 102 Browning Lane, Building B, Ste 1, Cherry Hill, New Jersey 08003 as counsel for the Plaintiff in the above entitled matter. The undersigned hereby consents to this substitution. Andrew Sklar, Esquire Superseding Attorney Sklar - Markind 102 Browning Lane, Bldg B, Ste 1 Cherry Hill, NJ 08003 ID # 65332 Joann Needleman, Esquire* Withdrawing attorney Maurice & Needleman, P.C. 935 One Penn Center Philadelphia, PA 19103 ID#74276 Dated: March 29, 2012 Dated: March 29, 2012 * Signed with permission of Joann Needleman, Esq. FILE NO.: FT 110496 Andre,, Sklar, Esquire (ID#65332) Lloyd S. Markind, Esquire (ID #52507) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: FT 110496 Attorneys for Plaintiff Pqb T!, APP -9 PIS 4: 4 "UMBERLANO Co Uj i y PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY Plaintiff(s) i No. 06-2580 V. Term DENNIS L GLESSNER and DIANE GLESSNER Defendant(s) CIVIL ACTION I PRAECIPE FOR SUBSTITUTION OF COUNSEL TO THE PROTHONOTARY: Kindly substitute Andrew Sklar, Esquire and Lloyd S. Markind, Esquire of the law offices of Sklar - Markind, 102 Browning Lane, Building B, Ste 1, Cherry Hill, New Jersey 08003 as counsel for the Plaintiff in the above entitled matter. The undersigned hereby consents to this substitution. "/ Andrew Sklar, Esquire (ID #65332) Lloyd S. Markind, Esquire (ID #52507) Superseding Attorneys Sklar - Markind 102 Browning Lane, Bldg B, Ste 1 Cherry Hill, NJ 08003 Jq,?fnn Needleman, Esquire* 'Withdrawing attorney Maurice & Needleman, P.C. 935 One Penn Center Philadelphia, PA 19103 ID#74276 Dated: April 2, 2012 Dated: April 2, 2012 * Signed with permission of Joann Needleman, Esq. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 's r 111 y' L Jody S Smith Chief Deputy L, e r? x 9 2: 2 Richard W Stewart Solicitor D SOU?dT'i i`t4 Ford Motor Credit Company I Case Number vs. 2006-2580 Dennis L Glessner (et al.) SHERIFF'S RETURN OF SERVICE 04/11/2012 09:34 AM - Elizabeth Muller, Deputy Sheriff, who being duly sworn according to law, states that on April 11, 2012 at 0934 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Dennis Glessner and Diane Glessner, 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 Joan L. Crowl, Teller Manager, 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 April 13, 2012 to Dennis L. Glessner at 9557 Olde Scotland Road, Shippensburg, PA 17257 and to Diane Glessner at 1210 Newburg Road, Shippensburg, PA 17257-8607. SO ANSWERS, &Z 7, - -April 12, 2012 RON R ANDERSON, SHERIFF Eli abeth Muller, Deputy i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY :No. 06-2580 Plaintiff VS. CIVIL ACTION DENNIS L GLESSNER and DIANE GLESSNER -" ' r- _ Defendant CD -r ? ld-nS? _ _ INTERROGATORIES IN ATTACHMENT .?! X71 ? - 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 to him (her/them) for any reason? 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 persons any property of any nature owned solely or in part by the defendant? k 0 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 the defendant held or claimed any interest? 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? 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 and what 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? 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 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 recurring basis. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 41 Pa.C.S § 8123? If so, identify each account. 9. How much is the value of any property in your possession belonging to the defendant(s)? FD Date: March 29, 2012 _ Andrew Sklar, Esquire (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. X10 0 \110 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: FT110496 Ltl i'i1 ,Jr? PI7 J• 1= D ! 'It'-IBERL,AND COW TY F 1 'EVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FORD MOTOR CREDIT COMPANY :No. 06-2580 Plaintiff TERM VS. CIVIL ACTION DENNIS L GLESSNER and DIANE GLES SNER Defendant PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the attachment as to garnishee, M&T Bank, in the above captioned action. Date: April 24, 2012 Andrew Sklar, Esquire Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Plaintiff vs. DENNIS L GLESSNER and DIANE GLESSNER Defendant :No. 06-2580 : CIVIL ACTION- LAW C-) Cl rnw -n z , -ur , -< o c > <CD -+C,) r' c7 C) z C- W C) CERTIFICATION OF SERVICE/COMPLIANCE Michael O'Neill, of full age, hereby certifies as follows: 1. I am a paralegal employed with SKLAR - MARKIND, Attorneys-at-Law. 2. On 2 v I `Z I served copies of the filed Praecipe to Issue Writ of Revival of Judgment and Writ of Revival of Judgment on Defendants, DENNIS L GLESSNER and DIANE GLESSNER , by sending them simultaneously by regular and certified mail, return receipt requested to: DENNIS L GLESSNER 9557 OLDE SCOTLAND ROAD SHIPPENSBURG PA 17257 DIANE GLESSNER 1210 NEWBURG RD SHIPPENSBURG PA 17257-8607 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dated: l Z I,( I Z MicNeill, Paralegal File No.: FT110496 SHERIFF'S OFFICE OF CUIUIBERLAND COUNTY Ronny R Anderson ~} Sheriff ~~ `~ - ~ !j -~~ Jody S Smith ,. t Chief Deputy ~ ~~ ~~ ~a~ ~ ,~il~ c~; ,° c Richard W Stewart Solicitor `~i11'~~~lt~.J;l~ti~ ~''~ a ~,., Ford Motor Credit Company vs. Case Number Dennis L Glessner (et al.) 2006-2580 SHERIFF'S RETURN OF SERVICE 04/11/2012 09:34 AM -Elizabeth Muller, Deputy Sheriff, who being duly sworn according to law, states that on April 11, 2012 at 0934 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Dennis Glessner and Diane Glessner, in the hands, possession, or control of the within named garnishee, A/I & T Bank, 1 W High Street, Carlisle. Cumberland County, Pennsylvania 17013, by handing to Joan L. Crowl, Teller Manager, 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 April 13, 2012 to Dennis L Glessner at 9557 Olde Scotland Road, Shippensburg, PA 17257 and to Diane Glessner at 1210 Newburg Road, Shippensburg, PA 17257-8607. 11/07/2012 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: $99.04 SO ANSWERS, November 07. 2012 RON ~ R ANDERSON, SHERIFF . 5 Z> l~L, ~,~t . ~~ ~~~y~ 1~~~ a ~ ~ Sys