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Home My WebLink About06-3000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL DIVISION Case No. ()~ - 3DOCl \ (};v;L~1l[ C & W ASSET ACQUISITION, LLC, vs. STEVEN E. HAMILTON and BEVERLY HAMILTON aIkIaBEVERLY A. HAMILTON COMPLAINT IN BREACH OF CONTRACT Defendants Filed on Behalf of Plaintiff, C & W Asset Acquisition, LLC Counsel of Record for This Party: James McNally, Esquire PA LD. No. 78341 METZ LEWIS LLC 11 Stanwix Street, 18th Floor Pittsburgh, Pennsylvania 15222 412-918-1100 Firm # 437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C & W ASSET ACQUISITION, LLC, Plaintiff, vs. STEVEN E. HAMILTON and BEVERLY HAMIL TON alk/a BEVERLY A. HAMILTON Defendants ) ) ) ) ) ) ) ) ) ) ) CIVIL DIVISION No. NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within TWENTY (20) days of this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE: Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (717) 249-3166 ! I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C & W ASSET ACQUISITION, LLC, Plaintiff, vs. STEVEN E. HAMILTON and BEVERLY HAMILTON aIkIaBEVERLY A. HAMILTON Defendants. ) ) ) ) ) ) ) ) ) ) ) CNIL DNISION No. DC. -.] 66b G-(.>~l~~ COMPLAINT IN BREACH OF CONTRACT AND NOW COMES C & W Asset Acquisition, LLC, by and through its attorneys, Metz Lewis LLC, files this Complaint in Breach of Contract and in support thereof avers as follows: I. C & W Asset Acquisition, LLC ("C&W"), is a limited liability company with a place of business located at 100 North Center Street, Newton Falls, Ohio 44444. 2. Steven E. Hamilton and Beverly Hamilton aIkIa Beverly A. Hamilton ("Defendants") are adult individuals with a last known address of 724 Shippensburg Road, Newville, Pennsylvania 17241-9313. 3. On July 18, 1996, the Defendants executed and delivered to NationsCredit Consumer Discount Company a Note ("Note") in the original principal amount of $5,655.64. A true and correct copy of the aforesaid Note is marked Exhibit "A", attached hereto and made a part hereof. 4. The Note was subsequently assigned and is currently held by C& Was assignee. 5. The Defendants are in default under the teIWs and conditions of the Note for, among other reasons, failure to make payments when due iJ![ accordance with the terms of the Note. 6. C&W notified Defendants of Defendants' default under the terms of the Note and demanded payment in full for the outstanding balance in connection therewith. True and correct copies of the demand letters sent by C&W to the Defendants are collectively marked Exhibit "B", attached hereto and made a part hereof. 7. Notwithstanding C&W's demand for payment, the Defendants have failed or refused to pay. 8. The amount due C& W by Defendants is computed as follows: Principal Interest (to 05/01106) $2,476.46 1.755.56 TOTAL $4,232.02 plus additional interest at the contractual rate of $1.67 per day, from May 1, 2006, plus late charges, attorney's fees and costs as permitted in accordance with the terms of said Note. 9. C&W has complied with all conditions precedent and is entitled to payment in full on the outstanding balance due on the Note. WHEREFORE, Plaintiff, C& W Asset Acquisition, LLC, demands judgment in breach of contract against Steven E. Hamilton and Beverly Hamilton a/k/a Beverly A. Hamilton, in the amount of $4,232.02, plus interest in the amount of $1.67 per day from May I, 2006, plus late charges, reasonable attorney's fees and costs. Respectfully submitted, --- By: a y, sq re PA LD. No. 78341 11 Stanwix Stree ,18th Floor Pittsburg!l1, Pe ,sylvania 15222 412-918-1100 . Attorneys for Plaintiff Exhibit "A" I I I NOTE LENDER: NATIONSCREDIT CONSUMER DISCOUNT COMPANY 3300 MART2DALE. STE 107 CAMP MILL PA 170017Z36 BORROWER: STEVEN 38 RAYS DRIVE NEWVILLE ACCOUNT NUMBEI C03418604 LOAN DATE 07-18-1996 E HAMIL TON SOCIAL SECURITY NUMBER 202-52-1473 PA 172419313 CO-BORROWER: BEVERLY 38 RAYS DRIVE NEWVILLE HAMIL TON SOCIAL SECURITY NUMBER 175-62-5280 PA 172419313 FIRST PAYMENT DUE DATE FINAL PAYMENT DUe DATE FIRST PAYMENT R,EGULAR PAYMENT FINAl. PAYMENT 08-21-1996 07-21-2001 . 162.63 . 166.70 . 166.70 PAYMENTS ARE TO BE MADE IN 60 CONSECUTIVE MONTHLY INSTALLMENTS AND ARE DUE ON THE SAME DAY OF THE MONTH AS THE FIRST PAYMENT. INTEREST PREPAID AMOUNT TOTAL OF CREDIT LIFE FINANCE CHARGE FINAN CEO PAYMENTS INS. PREMIUM . 4242.29 . 100.00 . 5655.64 . 9997.93 . 206.42 CREDIT DISA. BILlTY PREMIUM N1A N1A N1A N1A . 374.07 For value r-.oelvlldth. u~"'lgn.cljolntly and .....raIly promll..to ply to thl t..nd.r at the add,... dellgnated by the Lenar the total of payment..tated above, being the amount fin.nad plus the lnt....t and pl'llplild flnanol oharge ,tatlld abov.. In the ev.m or d.faultln the paym."to, the full amount of anylnltlllm.ma,tha BoI"l'OMI'I agrHlhattha)' ,halt plIylo the Lender an addlllan.loharo..t the r. of 1*% per month on the amount In IlfNlI untll.aIeI amount I. paid In full, but not 1M' than. minimum chlll'gI of OM dollar for any default or 10 or more day.. In the lIVent the payment of all wholly unpaid installmente I. extended by the Linder tor . period of on. or more full months, the Borrowers will pay an e~slon energe computed at the monthly rate of ,*% 01 the amount extended. Delault in tha payment of the fuU amount of tny lnstll/lment on tnl. Nota, at the option of tna Landa:r and without notioa or dam and, will rander the entira unplld baltnoa, I... unaarned oharge.,. once due and payable, Borrow<<'t ag,..to pay a onarge (not .xoHdlng $20.00) If any ohe~or other Inltrumenttaken In paymant ia aubaaqJantlydiahonorKI. Borrow.... &;,..e to keep any oolllll:erll/ln.u~ agll/nat 10" or damaga to Lander'. ..Isf.otlon .nd to name Lander .. . 10" p.y.. on any IUoh IMurance, II Pror>>rtY In.uranoemu.t t:. obtalnad at tn. time of thi.lo.n, Borrowatl may purohueit tnrough any In.uranoeoompanyor agent oftnalr choice. Borrowwa may aIao obtain ,*,onal property il'lluranOll through tn. Land.... Property in.urance availabl. througn the Lander doH not inolud.llabillty Il'IIuranOll of any kind. If Borrowers fall to kHP ooll.....I.III:I.faatorllyln.urad during the term of tnl.loan, Borrow.. n.,..by .uthoriz. Lander, III: It. option, to purch...I1lY taq1.l1r.d I".uranoa. Lander m.y .itn.r raquut Immedi.te ,.imbuts.m.mfrom Borrowatl for the coat of augh in.urance or m.y.dd tn. OOllt orthti In.ur.nOllto the unpaid bal.-.ce of this loan and oharg.lnl...t on It at the r. agraad to In thi.lo.n. Payment In advance may b. mad. in any amount .t .ny tim.. Upon full prep.ym.nt, a portion of 11'1. lnt...t wUI be refundlld If the oaioullll:lon duoribad in the ramaindlll'of thl.pwagraph re.ults in I refund. Th. portion to be rafunded.hall be th.t proportionoftha lntarut whlcn th.lUm of the monlhlYbalanoa. aoheduledto be oulatandlng during th. full month. following .uch prepaymenl in lull bears 10 the .um of all montnly balanoa. originally.ohaduledlo be outlltanding. However, no refund of I...lhan $1 will be made. If aU or tny part of tny l'IIaI estate Mouring thi.lo.n I. aold or Iranaferred witnout Landar" prior writt.n oon..m, l.ndf.r, al Land.r'.optlon, and In aooord.no.witn led....llaw, maydaola,.ln. .ntI,. balance Immedlat.lydu.. Tn. Borrow.1'8 .ev.rally waive d.mand and p,....ntm.nt for paym.nt, notice of nonpaym.nt, protut and notlo. of prot.st of this agre.m.nt or tn. dooum.nta .videnoing any loan made n'l'IIunct.r, and ag,...lhl.l tn.lr liabilltyahall not be alfaotad by an extenllonof tn. 11m. of paym.nt of all or any part of any amount owing on aooount of any .uch loan. Th. Borrow.1'8 n....by agraa to pay ,..aaonablt attomay', fe.., and actual court 00118, Ihould thll obligation ba rafarracl altar a.tsult 10 an attorney who il nol . .alaried .mploYftl of Lander. Thl. obllgatlon.nall oontlnu. following antry 01 judgment against Borrow...., or bankruptcyflllng by or against BolTOWllts, until all.um. dua have bHn paid to Lander, .. parmitlld by Plnnlylvanla I.w,. All p1urll worda uud n....in thall be oonatru.d In .ingularwn....th. lubjaat II Ilngular. IN WITNESS WHEREOF, tn. Underslgn.d have nareunto let thllr hancla and ..ais on the date .ppearing abov.. Signed, ..a1ed and dlliv.tad In tna prauno. of: WITNESS: Con /A; IJ(, ?1f\J l.. x ~c!.~ 0), '~6 (\ . tc:m... . ti".",-, Sonow.. (SEAL) WITNESS: x (SEAL) WITNESS: x (SEAL) Borrow.r WITNESS: x (SEA') Borrow.r Iltha prooHdsol tnl.loan a,.. applied In wholaor In .ubatantlal part to a PUl'Clh.,.of goods or urvloufrom a Sallarwho referredth, Borrowal'8 to the Lanct.r and th.gooda or ..rvlo..ware purch...dfor paraonal,family, or hOUlaholdu.., therjthe following notloa is appIioabl.: NOTICE ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT Is SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINBT THE SELLER OF <lOODS OR SERVICES OBTAINED WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. PENNVSLVANlA. OL FlEiNON-FlE FOAMPAOO82198 DISTRIBUTION: COPY 1. ORIGINAL; COPY 2. BORROWER'S COPY; COPY 3. 2nd BORROWER'S COPY Exhibit "B" I I I ! C & W Asset Acquisition, LLC. 100 North Center Street Newton Falls, OH 44444 888-462-2353 (888-GOCADLE) 1-888-462-2353 330-872-0918 FAX: 330-872-5367 February 14,2006 Beverly Hamilton 724 Shippensburg Road Newville, PA 17241-9313 RE: Note Originally Dated: 07/18/1996 Original Principal Amount: $5,655.64 Maker(s): Steven E. Hamilton, Beverly Hamilton Original Payee: NATIONS CREDIT Our File No. OF251092 Dear Beverly Hamilton: As you know, C & W Asset Acquisition, LLC. is the current owner of the above-referenced debt. You are hereby advised that your debt is in DEFAULT, and that C & W Asset Acquisition, LLC. hereby DEMANDS that you WITHIN 35 DAYS of the date of this letter pay the outstanding amounts of the debt in full. C & W Asset Acquisition, LLC. hereby makes DEMAND upon you for payment in full of all unpaid amounts through February 14, 2006, of $4,153.30, which includes the principal balance of $2,476.46, and accrued interest due through February 14,2006 of$I,676.84, due WITHIN 35 DAYS of the date of this letter. Interest accrues thereafter at $1.67 per day. Because of interest, late charges and other charges that may vary from day to day, the amount due on the day you pay may be greater. If you pay the amount shown above, an adjustment may be necessary after we receive your check, in which event we will inform you before depositing the check for collection. For further information, write the undersigned or call 1-888-462-2353, Ext. 3364. If the total amount due is not paid in full as indicated above, C & W Asset Acquisition, LLC. may pursue its legal remedies, which may include the filing of a lawsuit against you for the total amount due, plus court costs and attorney fees, if allowed by law in your state. IN ACCORDANCE WITH 15 U.S.C. 1692e(ll), PLEASE BE ADVISED THAT THE PURPOSE OF THIS LETTER IS TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. If you have any questions, please do not hesitate to contact me. I can be reached toll-free at 888-462. 2353 (888-GOCADLE), Ext. 3364 between the hours of 8:30 a.m. and 5 :00 p.m. EST, Monday through Friday. ~:very truly, ~~~lselY Account Officer KK:SM By Regular Mail- clm and Certified Mail- Return Receipt No. 70041350 0002 8843 5390 I,\shc:n\OFZS1092 Hamilton.doc I I C & W Asset Acquisition, LLC. 100 North Center Street Newton Falls, OH 44444 888-462-2353 (888-GOCADLE) 1-888-462-2353 330-872-0918 FAX: 330-872-5367 February 14,2006 Steven E. Hamilton 724 Shippensburg Road Newville, P A 17241-9313 RE: Note Originally Dated: 07/18/1996 Original Principal Amount: $5,655.64 Maker(s): Steven E. Hamilton, Beverly Hamilton Original Payee: NATIONS CREDIT Our File No. OF251 092 Dear Steven E. Hamilton: As you know, C & W Asset Acquisition, LLC. is the current owner of the above-referenced debt. You are hereby advised that your debt is in DEFAULT, and that C & W Asset Acquisition, LLC. hereby DEMANDS that you WITHIN 35 DAYS of the date of this letter pay the outstanding amounts of the debt in full. C & W Asset Acquisition, LLC. hereby makes DEMAND upon you for payment in full of all unpaid amounts through February 14, 2006, of $4,153.30, which includes the principal balance of $2,476.46, and accrued interest due through February 14, 2006 of$I,676.84, due WITHIN 35 DAYS of the date of this letter. Interest accrues thereafter at $1.67 per day. Because of interest, late charges and other charges that may vary from day to day, the amount due on the day you pay may be greater. If you pay the amount shown above, an adjustment may be necessary after we receive your check, in which event we will inform you before depositing the check for collection. For further information, write the undersigned or call 1-888-462-2353, Ext. 3364. If the total amount due is not paid in full as indicated above, C & W Asset Acquisition, LLC. may pursue its legal remedies, which may include the filing of a lawsuit against you for the total amount due, plus court costs and attorney fees, if allowed by law in your state. IN ACCORDANCE WITH 15 U.S.c. I 692e(1 I), PLEASE BE ADVISED THAT THE PURPOSE OF THIS LETTER IS TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. If you have any questions, please do not hesitate to contact me. I can be reached toll-free at 888-462- 2353 (888-GOCADLE), Ext. 3364 between the hours of 8:30 a.m. and 5 :00 p.m. EST, Monday through Friday. KK:SM By Regular Mail- clm and Certified Mail - Return Receipt No. 7004 1350 0002 8843 5406 I'.sherj\OF~5109~ HamiltondQc Q5-18-0e 11 :290m From-METZ LEWIS LLC t. o o I ' 4129181180 HOT P. De/De HT4 VERIFICATION I, Knsri Knisely, in my position as Account Officer of C&W Asset Acquisition, LLC, depose and say subject to the penalties of 18 Pa. Cons. Stat. Ann. 94904, relating to unsworn falsificanon to authorities, that the facts set fonh In the foregoing Complaint in Breach of Contract arc rrne and correct to the best of my personal knowledge, information and belief. C & W ASSET ACQUISITION. LLC By (') -k}. .--, ~ ~ l.Jt. 0 c-=' t::.=> N 1- ('" cr~ ~-n U\ ~ i- P: rt;= -- en ~o U\ N (,'~),(:) .- .......... C> -,...' ..(, L-..." ........ --0 f~~ C"') ~ ~ ~ -"". ;3)[1"1 ~ r:-: ~c.\ ,~ -{) U'I :,., ;..(. ~ D cr'. -$) 1- . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C & W ASSET ACQUISITION, LLC, CIVIL DIVISION Plaintiff, No. 06-3000 vs. STEVEN E. HAMIL TON and BEVERLY HAMILTON a/k/a BEVERLY A. HAMILTON PRAECIPE FOR DEFAULT JUDGMENT Defendants. FILED ON BEHALF OF: C & W Asset Acquisition, LLC COUNSEL OF RECORD FOR THIS PARTY: James McNally, Esquire PA LD. No. 78341 METZ LEWIS LLC 11 Stanwix Street 18th Floor Pittsburgh, PA 15222 412-918-1100 Firm # 437 , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C & W ASSET ACQUISITION, LLC, Plaintiff, vs. STEVEN E. HAMIL TON and BEVERLY HAMILTON a/k/a BEVERLY A. HAMILTON, Defendants. ) ) ) ) ) ) ) ) ) ) ) CIVIL DIVISION No. 06-3000 PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY Please enter a default judgment in the above-captioned case in favor of Plaintiff, C&W Asset Acquisition, LLC, and against Defendants, Steven E. Hamilton and Beverly Hamilton a/k/a Beverly A. Hamilton, in the amount of $4,332.02, with interest thereon at the contractual rate of 6% per annum from July 1,2006, plus reasonable and actually incurred attorney's fees and costs. Dated: -1 /5 JtJ " I I Respectfully submitted, By e Pa. LD. #783 Attomeys fo C&W Asset Acquisition, LLC, Plai ff II Stanwix Street, 18th Floor Pittsburgh, PA 15222 Phone: (412) 918-1100 . AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) ) ) SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared James McNally, Esquire, attomey for and authorized representative of Plaintiff who, being duly swom according to law, deposes and says that Defendants, Steven E. Hamilton and Beverly Hamilton aJk/a Beverly A. Hamilton, are not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. EALTH OF PENNSYLVANIA NatartaI Seal DIlwl K Sweeny. NoI8ry PubIc CllrOl~. AIeglenyCcmy Ii\I c..~....., Elq:lOes Apt" 12.2llO8 , PennayIvanJa _n Of Nota".. . EXHIBIT "A" v ( IN TIlE COURT OF COMMON PLEAS OF' CUMBERLAND COUNTY, PENNSYLVANIA C & W ASSET ACQUISITION, LLC, Plaintiff, vs. STEVEN E. HAMILTON and BEVERLY HAMILTON alk/a BEVERLY A. HAMIL TON Defendants TO: Beverly Hamilton a/kIa Beverly A. Hamilton 724 Shippensburg Road Newville, P A 17241-9313 DATE OF NOTICE: June 21, 2006 ) ) ) ) ) ) ) ) ) ) ) CIVIL DIVISION No. 06-3000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIlTEN APPEARANCE PERSONALLY OR BY AlTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECflONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF TInS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE TInS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TInS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TInS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCmS THAT MAY OFFER LEGAL SERVICES TO ELlGmLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 Sontb Bedford Street Carlisle, P A 17013 (717) 2411-3166 METZ LEWIS LLC By: James M ally, Esquire PA ID 0.78341 II S wix Street, 18th Floor Pi burgh, Pennsylvania 15222 412-918-1100 Attomeys for Plaintiff ( . ( \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C & W ASSET ACQUISITION, LLC, Plaintiff, . vs. STEVEN E. HAMIL TON and BEVERLY HAMILTON a/k/a BEVERLY A. HAMILTON Defendants TO: Steven E. Hamilton 724 Shippensburg Road Newville, PA 17241-9313 DATE OF NOTICE: June 21, 2006 ) ) ) ) ) ) ) ) ) ) ) CIVIL DIVISION No. 06-3000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRfITEN APPEARANCE PERSONALLY OR BY ATIORNEY AlID FILE IN wt.mNG 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 RIGHfS. YOU SHOULD TAKE TffiS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 AGENCmS THA T MAY OFFER LEG,u SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberllnd County Bu Assoclltlon 32 South Bedford Street Clrllsle, P A 17013 (717) 249-3166 B METZ L LLC squire 1 15222 . l ~ ~ ~ \to 1:. 0 -n -, , - -1 () ..,... n,11 -.' m:D - 0 f'"" r' P\ - - -rJ rn ~'.JC:; ~ f' -V 0 ("'.' (L,: ~ N -'\.! ;r.~ :~, : U'\ p:.. -,,,"" ) ~ '-.! 'n '-I J:.,,) ...c: $? -'.-,', - <r; ~ .j:' -< 1:- ~. '.. SHERIFF'S RETURN - REGULAR CASE NO: 2006-03000 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND C & W ASSET ACQUISITION LLC VS HAMILTON STEVEN E ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HAMILTON STEVEN E was served upon the , 2006 DEFENDANT at 724 SHIPPENSBURG ROAD , at 1155:00 HOURS, on the 31st day of May NEWVILLE, PA 17241-9313 by handing to BEVERLY HAMILTON, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 14.08 .00 10.00 .00 42.08,/ Qw... 1- I? ~P(, Sworn and Subscibed to before me this day of So Answers: .~~~~ R. Thomas Kline 06/02/2006 METZ LEWIS LLC BY~~M4_ _A. Deputy Sherif~ .. A.D. wi .. SHERIFF'S RETURN - REGULAR CASE NO: 2006-03000 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND C & W ASSET ACQUISITION LLC VS HAMILTON STEVEN E ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HAMILTON BEVERLY AKA BEVERLY A HAMILTON the DEFENDANT , at 1155:00 HOURS, on the 31st day of May , 2006 at 724 SHIPPENSBURG ROAD NEWVILLE, PA 17241-9313 by handing to BEVERLY HAMILTON a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. 0- Sworn and Subscibed to 6.00 .00 .00 10.00 .00 16 . 00\1' '"'In /o~ So Answers: ~?'./ .& ~ 0>''9-''';'''' '-?/.' r ...-: ..c$.,ejY;." """"':.4li...-t"~_';':'t....r---P Sheriff's Costs: Docketing Service Affidavit Surcharge R. Thomas Kline 06/02/2006 METZ LEWIS LLC before me this day B~aohd-~~~ Deputy Sherlff of A.D. OF251092 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEAL TH OF PENNSYLVANIA C & W ASSET ACQUISITION, L.L.C, Plaintiff vs. DOCKET NO. 06-3000 STEVEN E. HAMIL TON and BEVERLY HAMILTON a/k/a BEVERLY A. HAMILTON, Defendants. SATISFACTION OF JUDGMENT WHEREAS, C & W ASSET ACQUISITION, L.L.C, received a judgment against STEVEN E. HAMIL TON and BEVERLY HAMILTON ajk/ a BEVERLY A. HAMILTON, for the amount of $4,332.02 plus interest, attorney's fees and costs. Said Judgment was entered In The Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, on July 25,2006, under Docket No. 06-3000; and VVHEREAS, C & W ASSET ACQUISITION, L.L.C, now recognizes that said judgment has been settled in full; and NOW, THEREFORE, C & W ASSET ACQUISITION, L.L.C, does hereby release and discharge the judgment and any and all liens pertaining to said judgment. EXECUTED this 1 day of January, 2007. C & W ASSET ACQUISITION, L.L.C By:... Company I 5 Manager By: o D. Gluckner, Assistant Vice President I ~ ST ATE OF OHIO COUNTY OF TRUMBULL Personally appeared before me, the undersigned, a Notary Public in and for said State and County, duly commissioned and qualified, Jon D. Gluckner, with whom I am personally acquainted, upon oath, acknowledged himself to be Assistant Vice President of the within named bargainor; and that he, as such Assistant Vice President, being authorized so to do, executed the foregoing instrument for the purposes therein contained by signing the name of the partnership by himself as such Assistant Vice President. Date: 1- q - 0 7 Notarx.,,!:~bliLa I'Yi I JlJSh /I J, hP 0 .....{p.~lAL.s~.... ~ U /~o ." '1(\ ~ ", \. '" FFER i.'.'." 'Oi, \ !lNlY A. SHA NOl:arv l)ubHc, State of Ohio \. 15' o! My Comnl!ssloo Expires 04-10-08 ..../~!~ Or q~:.;'" ."~I"J"~~' . This instrument was prepared by Victor O. Buente, Jr., General Counsel, 100 North Center Street, Newton Falls, Ohio 44444, (330) 872-0918. ;:t.. r (') ~;. ~ I .~ '"' Q , ...0 <;'... ~ r-) '0? 9 :::3~--~' n -\ :r: ~., rnc :gl:!J .,~: )~. -" j '-.-.) .' -'-i --':"~ <- :r.-'" :;.t,;: v...... ~ ~ '6 . .> ~:.~ >'" \....' ~~~1 en ?~~ -< J..-