HomeMy WebLinkAbout02-1966ALAN S. CARPEL, ESQUIRE
Identification Number: 12048
1129 Spruce Street
Philadelphia, Pa 19107
(215) 238-7700
Consumer Portfolio Services Inc. :
16355 Laguna Canyon Road :
Irvine, California 92618 :
vs. :
Max G. Manwaring and :
Janet B. Manwaring :
146 West Park Street :
Carlisle, Pa 17013 :
COURT OF CO~ON PLEAS
OF CUMBERLAND COUNTY
NOTICE TO PLEAD
You have been sued in court. If you wish to defe
the claims set forth in the following pages, you must t
within twenty (20) days after this complaint and notice a
by entering a written appearance personally or by atl
filing in writing with the court your defenses or objecti
claims set forth against you. You are warned that if y
do so, the case may proceed without and a judgment may
against you by the court without further notice for
claimed in the complaint by the plaintiff. You may los
property or other rights important to you. This and ~
communication from our firm are attempts to collect a
information obtained will be used for that purpose.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELl
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LE(
CUMBERLAND BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 1 7013
71 7-249-3166
~d against
~ke action
re served,
:orney and
ons to the
)u fail to
~e entered
any money
:. money or
~ny future
debt and
IF YOU DO
~PHONE THE
~L HELP.
ALAN S. CARPEL, ESQUIRE
Identification Number: 12048
1129 Spruce Street
Philadelphia, Pa 19107
(215) 238-7700
Consumer Portfolio Services Inc. :
16355 Laguna Canyon Road :
Irvine, California 92618 :
vs. :
Max G. Manwaring and :
Janet B. Manwaring :
146 West Park Street :
Carlisle, Pa 17013 :
COURT OF COM~ION PL1 AS
OF CUMBERLAND COUNTY
CIVIL ACTION
1. Plaintiff is Consumer Portfolio Services, Inc.
2. Defendants are Max G. Manwaring and Janet B. M~nwaring.
3. Defendants entered into a Contract dated 02/26/98 for the
purchase of a 1994 Acura Integra, Vehicle Identificatioh Number
JH4DB7552RSO05046, more fully described in the Contract, a copy of
which is attached hereto, made a part hereof and marked as Exhibit
4. The defendants defaulted under the terms and conditions of
said contract therein by failing to make said payments as set
forth, i
5. The vehicle has not been returned and defendants are in
possession of the aforesaid vehicle.
6. Under the terms and conditions of said contracl
vehicle is subject to be retaken by plaintiff and is sub
possession and control.
7. By virtue of defendants defaulting in failing to make
payment, plaintiff has elected to take possession of sa~d vehicle
in order to protect its interest therein.
8. Plaintiff has made demand upon the defendants
of said vehicle and hereby demands the return of same,
defendants have refused to peacefully surrender same pu
the terms and conditions of its contract with the plain
9. That the value of the vehicle is approximately
$9060.00.
WHEREFORE, plaintiff demands judgment in replevin
Defendants, Max G. Manwaring and Janet B. Manwaring, for
of said vehicle.
the said
~ect to i ts
against
)ossession
BY:AL~.CARPEL, ~SQUIRE
Attorney for Plaintiff
1129 Spruce Street
Philadelphia, Pa~19107
(215) 238-7700
for return
but said
rsuant to
~iff .
VERIFICATION
this action and verifies that the statements made in th~foregoing
m~tter are true and correct to the best of his or her ~owledge,
info~tion and belief. The undersigned understands that the
statements herein are m~de s~bject to the penalties of 1i8 Pa. C.S.
Section 4904 relating to unsworn falsification of authorities.
'A~.iAIL IH$¥k, LLMENT'
· CONTRACT
AND SECURITY
AGREEMENT
No,
Date 02/26/98
AUTO-MAX OF CARLISLE
1t10 HARRISBURG PIKE
Buyer
MAX O MANWARING
Address .~ANET B MANWAR ! NG
145 CREEK ltd
CARLISLE~ PA. 1'/013 NEWVILLE, PA 17241
Seller means the S~ller above amd anyone to ·
, _ whom the Selle_r trantlfem this Contract. Buyer ir, em= ~T~', Buyer above.
~uAr~LE:e~eB~uy~erv~;~r~=s,~_pu~r~.,,_.a~. ~ mptor veh. icle (Vehicle) and ,,rv:ce~ dascn'bed below from Seller. Buyer agrees to
~. w'-' ,--- '::.'- '--- ....... .,,,, oeser on The terms of this contract and security agreement (Contract). Buyer' understands that
os,er ~s Selling uuy~r the Vehicle In its present corldl/fan.
I~a~,;,-~;on of Year ~994 VIN JH4DE7552RSO05046 Other:I
Motor Vehicle Make ACURA IJc. No./Year
Purchased Model I NTEGKA [] New [] L/Z~d
Trade-In .~_ 0
PROMISE TO PAY AND PAYMENT TERMS: Buyer promises to pay Seller the principal amount of $ ; 5 ~ C 2.20
Buyer agrees to pay finance charges on the unpaid balance at _ 21_ . 0 n_ 0 % per year from today's ISle until maturity.
Finance charges accumulate on a 36 ~ day basis,
unoAa.f~r2~.~..~ty.?r after i~u~ermb~m make. any of the terms of th,s Comb'act or after a court judgment, Seler will e~ interest on the
year. uye agree to make payments and to pay fate charges s provided in ~he
TRUTH IN LENDING DISCLOSURES. Buyer also agrees to pay any addHonal amounts according to this Co s terms.
[] MINIMUM FINANCE CHARGE: Buyer agrees to pay a minimum finance charge of $_ If Buyer pays this
Contract in full before Seller has earned that much in finance charges. ~!/'A
DOWN PAYMENT: Buyer agrees to pay or apply to the Cash Price, by the date of this Contract, any ca= ;h, rebate amd net
trade-in vaJue descn~ed in the ITEMIZATION OF AMOUNT FINANCED, [] Buyer agrees to make payments Over an extended
perfed of time or at a future dale as Part of the cash down payment as shown in the payment schedule n the TRUTH IN
LENDING DISCLOBURES-
~..wn~an~.,~.,y~_r., ~ pu~.r~.._a.~_ ~ crc(fit, incluaing
' uuyers do'
21 .000
Pa ment Schedule: Bar's a ent schedule is - '~
Number of Pa ants Anlo~nt of Pa n~ W ~.p ents'A~e Due '
60 [MONTHLy Beginning ~ARCH 28,
~ Se-~Jrlty: Buyer is giving Seller a security Interest in the Motor Vehicle purchased.
~ [] 7AJate Charge: if & payment is mom than ~ days late, ~fller will charge Buyer .,
· eno prepayment remn~ ar~ pe
RICT1ONS: If Buyer does not meet this Contract's obligations, Buyer may tcoe the pr( erty that
fa.
SECURITY: To secure Buyer's payment and performance ~nde; this Contract, Buyer gives Seller a secudty inl
.,~.., ,,._ __, ~,= ~mu amy i[ems ins[aJieu o~' piac. eon or on me vehicte as pmrmr~ mu.er al~ .h, r' on the Vehicle.
:~,.=Z==~ ,n .me p.~ of any sale of the Prepertv. Seaer's intsm,=f .,;l~ .~* =.,*....~ ,. ;-..:.2f.r."' :'-' .--T~T' '.';~ ~,_v Seller a securfly
uo me goo<Is witran 10 days alter Setter ente~ i,~M*~;o c.._,._--'_'T:J:"L'_'¥'~ .... ,- .¥ ~??um~.f .,l~s unless u. ~r acqlJfl'es rights
,...~ .,,o ,.~,,,.a~ u~ um gcoas are instaileQ Jn or affixed to the Vel
CREDIT INSURANCE: Cred, t life tnsurnnce and creel;
~nt~a
Molor Vehiole Price
~ ConLmct* SHART
~ ~lldu~l~ll Imeunl for ~he ktlurln~t may ~l
~ N/A . Il ~ ~ I~u~ f~
or ~ ~r. ~we ~ S
for of
~$ ~/A ~.~~.~ N/A
The ptope~y Insurance must protect against loss
phial d~e, B~ ~ n~ 8el~r ns ~e~ela~
the in~ra~ ~, ~l~r m~ ~ulm addlUo~l
be~m ~tl?.~a ~ to use Ma~ p~ ~ m~ir
or rep ace me ~mpe~, Buyer w I pay all amoun~ that
[nsu~ce d~s not ~er,
If B~t f~ ~ o~n or k~p insu~ or to name Seller
~ ~efl~a~LSeller ~y ob~ insu~ce to pr~e~ ~¢s
ntem~ in t~e ~pe~. ~Rer wZIl ad~ ~& ~ of ins~ to
· e amour Buyer ow~ ~, A~ a~ Seller ~ys for
tnnu~ ls due im~a~ly ~d will earn I~em~ at
cha~ a~r
TRANSFER: Seller tran~fem this Cont~ to
CON~LIMEFI PORTFOUO SERVICF..~, INC.
2 ADA, IRVINE, CA g2618 PH# Bg0-443-2588 __.
(Transferee) [] with legal liability [] without legal Jiabtlity
trader the temm of the ~ BY SELLER section.
se,ec.__~ ..-- ______-~FT°-I~Cx o~ [:.*~L [ s~.
NOTICE TO BUYER
DO NOT SIGN THIS CONTRACT IN BLANK.
BUYER I$ ENTre_ED TO AN EXACT COPY
OF THE CONTRACT BUYER SIGNS. KEEP
IT TO PROTECT BUYER'S LEGAL RIGHTS.
.' ...... ....... . .
BY SlGNING BELOW BUYER AGR S TO
THE TERMS ON PAGES 1 AND 2 OF THIS
CONTRACT AND ACKNOWLED6E$
RECB¥1NG A COPY OF THIS CONTRAC?. !
Buyer:
Slg~ffu~..~.----~ - I~
f19.~9~/OR
Si~n~e ~ Dal~ -
=l~i~ ~NSYLVANIA RETAIL IN,.%'TALLMENT (X)NTRA~T AND $C-CURITY AGREEMENT~
{~ ~llWg/s~'~i'inc.~l-~uN('t'~04074341| F~n~R~81-MV'PA~[~7 f.~' MOTOflVEHICLE-NOTFORMAWUFACTUR~:)HOME~
ludgment. ,
J. Buyer makes any '~rltte~ statement ~lovidas any
financial information to Seller Iha"R~~ untrue or
in~ccurata.
K. Buyer permits any interest In the P .r~e. rty Io become
above or greater than Seller's interest m the Property.
L. A~y of Bu~/er's other creditors make the entire debt
M.A court order for a motley judgment or a money
judgment against Buyer becomes final.
N. Buyer falls to keep any promise made in connection
with this sale.
If Buyer breaks any of the terms of this Contract, Buyer
agrees to pay court costs Seller spends to collect amounts
Buyer owes. In addition, Buyer agrees to pay reasonable
attorneys' fees if Seller refers this Cpntr~L~t to an .a~rcey
~or collection.
If them is more than one Buyer and any one of the Buyers
breaks any agreement made In this Co~tra.ct,_Saller may
exemise Seller's rights a~ainst each Buyer or aa uuyers.
SELLER'S RIGHTS: If Buyer breaks any of the terms of
this Contract, Seller may exercise a. ny or allof Seller's rkj,hts
under law and this Confl'act: .
A. Seller may pay taxas, fees, expenses, or
the Prapmly or make repairs to the Property if Buyer
has not done so. Seller is not required to do so. Seller
will add any amount Seller pays to the amount Buyer
owes Seller. Thl~ amount is due immediately. This
amount will earn interest trom the date Seller paid It at
the rate that applies after maturity.
B. Seller may require Buyer to make the Property
available to Seller at a place Seller designates that is
reasonably convenient to Buyer and Seller.
marked on the front of this Contract and each such type of
coverage will be written by tji~iesursnce co~mpany named.
only the person signing the i~ for such if aurance. The
amount of charge Is indicated for each rpe of credit
insurance to be purchased. The term of ~surance will
commence es of the date the indebtedness Incurred and
will expire on the odginal scheduled ma~l ' date of the
indebtedness. Subject to acceptance by th~ insurer and
within 30 days, there will be delivered to the i, sured debtor
a certificate of insurance more fully de mcribing the
insurance. In the event of prepayment o~ the ndabtednass,
a refund of Insurance charges will be made wi~ an due.
NOTICE: ANY HOLDER OF THIS CONSUIV
CONTRACT IS SUBJECT TO ALL CL.
DEFENSES WHICH THE DEBTOR COUi
AGAINST THE SELLER OF GOODS OR
OBTAINED PURSUANT HERETO OR
PROCEEDS HEREOF. RECOVERY HERE
THE DEBTOR SHALL NOT EXCEED AMO
BY THE DEBTOR HEREUNDER.
IF BUYER IS BUYING A USED VEH
INFORMATION BUYER SEES ON TH[
FORM FOR THIS VEHICLE iS PARt
CONTRACT. INFORMATION ON THE WiNI
OVERRIDES ANY CONTRARY PROVISK
CONTHACT OF SALE.
TRANSFER BY SELLER
This season of this C~ntract allow~ Seller to transfer ~ Conlraat to a third party. This section does r~t aPl
~d~er transfers to the party llated in the TRANSFER section on this Contract ['Transferee) all of Seller's ril
Interest in this Contract. Seller gives TransfUse power, either in Trsnsferee's own name or in Seller's name, to ti
which Seller could have taken under ~his Contract.
Seller assures Trane_fares of the fqllowing.
A. This Contract represents a sale by Seller to Buy:'r.
B. The stalemants contained in this Contract are tree and correct.
C. Buyer paid the down payment exactly es stated.
D. The sale was completed in accordance with all applicable federal and state laws end regulations.
E. This Contract is vaEd and enfomeable.
F. The names and signatures on this Contract are tree and correct.
G. This Contract is not subject to any claims or defansas on the part of Buyer.
H. Seller delivered a completely filled-in copy of this Contract to Buyer st the time Buyer signsd this Contract.
L Seller delivered the Vehicle. to Buyer in good condition and Buyer accepted the Vehicle.
If any of Ihese assurances are broken or untrue, Seller wB, upon Transferae's_ request, repurchase Ulis
Transferee. Seller will repurchase this Contract.in cash [n Ihs amount of the unpaid balance, Including intt
expanses of Transferee, Including attomeye' fees.
Sailer will repay Transferee for any loss sustalced by it because of a court ordered deduct/on of the amou,
Transferee. Seller will re~y Transferee for any loss sustained by it as the result of a recovery made against Tr~
Seller gives up its rights to notice of acceptance of this Transfer, non-payment, non-performance, or any olh
Transferee.
Transferee may change the terms of this Contract with Buyer and any other person obligated under
Transferee may do so wi~out notice to Seller and without affecting the legal reapons~illl~es of Seliar under this'
WITH LEGAL LIABILITY: If ~ Transfer is mede 'with legal liability" as indicated in the TRANSFER s
Contract, Transferee takes this Transf.er with cardin legal rights against Seller. Seller agrees that if Buyer 1
perform according to the terms of this Contract, Seller will, at Transferee's request, repurchase this Contn
repurchese this Contract for the anmunt of the unpaid balance, IncltKilng finance chlu'ges, due at that time.
, WITHOUT LEGAL UABILITY: If'this Transfer 'ts made 'without legal Ilabflify" as Indicated in the TRANSF
this Contmc~Transferee takes this Transfer without liability to Seller except as provided above.
ER CREDIT
UMS AND
D ASSERT
SERVICES
WITH THE
UNDER BY
LINTS PAID
CLE, THE
WINDOW
OF THIS
IOW FORM
NS IN THE
:ly to Buyer.
ihts, title and
,ks all actions
~ontracl from
rest, plus the
~t Buyer owes
~sferae.
~r notice from
his Contract.
'rar~fer.
~ction on this
~lls to pay or
,et. Seller will
section on
RETAIL INSTALLMENT CON'~RACT AND SECURITY AGREEMENT ,
tToOTAL S ~A~... PBICE: S .e~er g;we Buyer the opportun~
pumnsse t~e Vehicle add 'described services for the
Cash Price or the Total ~ Price. The Total Sale PHce Is
~e tetai Ixice of the .Vehicle_and any services if you buy
am over a pedod of time. uuyer is purchasing the items
over a pealed of time.
The Total Sale Price shown in the TRUTH IN LENDING
DISCLOSURES assumes that Buyer will make all payments
es scheduled, Buyer may actually pay more or leas
depending on when Buyer makes payments,
Seller charges and collects finance charges. These
charges are not more then state or federal law altow~s, [f
Buyer pays a finance charge or fee that Is more than state
or federal law allows, Seller will apply the charge or fee first
to reduce Ute principal and refund any excess to Buyer.
.. Buyer..u~derstends ;md ag?es that soma payments to
other remunem~n,
PREPAYMENT: Buyer may prepay th s Contract ~n full or
in ~ ai ar~y. b.'me.. Any partial p~payment will not excuse
.any. ~er scneautea pe .yrr~.e~ ~ Buyer pays Utls Contract
in lull. uuyer may obtain trom Seller or the Insurance
company n. amed In B.uyer's po~cy or certificate o~ insurance
e reruns or m~/prepaid, unearned insurance premiums.
BUYER'S RF.~PON~IBIUTIES TOWARDS PROPERTY:
Buyer agrees to do Ute lo,owing:
A. Buyer will de[end Seller's security interest in the
.Property against anyone who claims to have an
mtsresf In the Property. Buyer will do whatever is
necessary to keep Seller's claim to the Property
ahead of the claim of anyone else. Seller's claim to
the Property comes ahead of the claim of any of
Buyer's other cmdi[ers. Buyer egress to si~n any
additional documents and to provide Seller w~th any
~,dditional informatia~ Seller may require to protect
,Seller's sscuHly interest in the Property.
B. Buyer will keep the Properb, in Buy. er's possession
and in good condition. Buyer w~ll only use the
P..roperty for its tnt .e~.ded and lawful purposes. Unless
otherwise agreaa in writing, Buyer will keep the
Pmpen'y at Buyer's address ~ted on this ContmcL
C. Buyer will riel put the Property up for sale without
written permission from Seller. Buyer wffi not transfer
any rfghts in th.e Property without first galling Seller's
wntten permiasmn.
D. Buyer wilt pay taxes, fees and expenses on the
Property when due.
E. Buyer will notify Seller of any loss or damage to the
Pmpe~. Buyer will provide Seller reasonable access
to the Property for Ute purpose of nap~ct on Seller
may lawfully enter and inspect the PmPeyty.
BREAKING THE TERMS OF THIS CONTRACT:
~oYer agrees Utai Ihs fol~,owing are eddll]onal terms ct this
ntract. Buyer will have broken the terms of this Contract
il one or more of the following occurs (except as proh~bitsd
by law):
A, Buyer fails to maJ~ a payment due under this Contract.
B. Buyer dies.
C. Buyer is Invotved th any insolvency or bankruptcy
proceedings.
D. Buyer fails to Reap the Property Insured, If required.
E. T~.e Property is substantially damaged, destroyed or
F. Buyer uses the Property in violation of any rule,
regulation or government order.
G. The Propezty is taken by any government authorities.
H. A money lud~mertt or tax ilen ts filed, aoai~ Buyer.
Buym's obligations.
D..Exc~. t when prohibited by law
mr additkmal amounts if the
pay all amourda Buyer owes
Seller may take any or all of t
above. Seller's decision not to take,
not'mean fhai Seller has [cst the
actions in the future. '
In addition, Seller may require
Immedfately, the remaining b~mce
llrmn .c?..c .,~.and all 9ther .~gree~
any ?'me mlm~mg: * ·,
A. Buyer falls to pay one or mon
under this Contract.
B. Buyer f~dle to pay taxes levied
C. Buyer fa~s to fum~h proof of
&galnst the Pmpmty.
.. D. Buyer ~ Ute Property for ills
Seller will mail to Buyer's last
required notice of an Intended
Properly. Buyer egress thai notfce Is
Buyer's I~ known ~ddmas, ~s reflm
Buyer agrees lhet holloa ma led
intended, sale o~ transfer (or such
.req~dred by I~w) Is reasonable.
~uyer.eg~_e~ that Seller may t~k~
in or on me Property subject to Buy~
personal property.
RESUMING CONTRACT: if Selh
Property, Seller may return thla Conb
end return the Property to Buyer.
Contract if Buyer pays all past due
Buye.r. ~c~.rrentiy owes, plus any o~e
lawfuny cue to Seller under Utla Contr
Buyer agrees topay for the
tal~as Ute Property through legal act
tak~ the Properly, Buyer must pay ti'
repmnng, cna storing tim Property
Seller may only collect expenses
1.5 days passed ~om Ute day Buys!
~:antmct to the day Se~r took the
EACH AND EVERY BUYER R
Buyer.who. signs this Contract agree
m:coroing to ~ts terms. This mesns
A. ~.uye~r ~s responsible for paying
mis c:ontraot even if another
B. S~eller may hold any Buyer reel:
Co~tract, even if Seller chock,
right to hold any other Buyer res
C. Seller may give up Seller's in~
end each Buyer Is still respo~
D. If Seller gives up any of Seller's
Buy~'s mapons~llily to pay thb
E. If Seller extends new cmcrd or
will not affect Buyer's respc
WARRANTY: Warranty information
separately.
NOTICE OF PROPOSED INSUR,
nf th~s Contract h~.mhv tekp(~'~ nofic
/
C. Seller may Immediately tails back the Property by
lawful means. In tsklr~fhe Properly, Seller may not
unlawfully enter onto Buyer's premisea or cause a
public disturbance. Se_lie[. may ~.1 Ihs Properly. Seller
.may.apJ.~ly..an.l. ourllS ~aller re~eivas aa provided by
laW ~o =micra reasonable expenses and then to
, Seller may sue Buyer
~ceede of a sale do not
,~ler.
~ actions described
~y ct the actions does
~lt to take any of the
;~uyer to pay Seller
the amount linanced~
cha~gas if Buyer does
~ installment payments
galnst the Property.
Iai purposes.
known address any
.la or transfer of the
reasonable if mm'led to
ted in Seller's records.
ten days before the
other period of time
r,Psersonal property
dght to recover the
~r has taken back the
act to its former stains
Seller will return this
Inslallments, interest
rt~.c~arges or aroounte
~ of a lawsuit if Seller
~n. At Ute time Seller
e expenses for taking,
allowed by law.
~roke the terms of Ihts
party.
SPONSIBLE: Each
s to pay ~ Conb'act
amounts owed under
~er hes signed Ihts
~ns~ble for paying this
s to give up Sallar'a
~or~ibis.
~rest In the Property
~slble for paying this
~ntS, it will not
tract.
mew~ this Contract, it
risibility to pay this
is provided to Buyer
[NCE: The Signer(s}
that amuo credit I~e
DfPAETM£N¥ OF TEANSPOETATION
CERTIFICATE OF TITLE FOR A VEH
CD~'U~qE~
039301
C~NSUNER PORTF~O
SERVZCE5
P 0 BOX 570710
[RVINE CA 926[9
tCLE
>/Pl'
~-~.x.~,~ "" '"
BILAI L 'RALLORY
$1GI1 tN PRE.~IENCE OF A hlOTARY
SHERIFF'S RETURN -
CASE NO: 2002-01966 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERI2LND
CONSUMER PORTFOLIO SERVICES IN
VS
MANWARING MAX G ET AL
REGULAR
DAVID MCKINNEY , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
MANWARING MAX G the
DEFENDANT , at 2058:00 HOURS,
at 146 WEST PARK STREET
CARLISLE, PA 17013
MAX MANWARING
on the 26th day of April , 2002
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.45
Affidavit .00
Surcharge 10.00
.00
31.45
Sworn and Subscribed to before
me this /~ day of
~ ~ A.D.
IP~othonotar~ --~ , ,
So Answers:
R. Thomas Kline
o4/29/2oo2
ALAN S CARPEL
Deputy she'rl f f ~
SHERIFF'S RETURN -
CASE NO: 2002-01966 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CONSUMER PORTFOLIO SERVICES IN
VS
MANWARING MAX G ET AL
REGULAR
DAVID MCKINNEY , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
MANWARING JANET B the
DEFENDANT , at 2058:00 HOURS, on the 26th day of April
at 146 WEST PARK STREET
, 2002
CARLISLE, PA 17013
JANET MANWARING
a true and attested copy of
by handing to
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
Sworn and Subscribed to before
me this /~- day of
/ ;-Pr6~h0no~-a~ ! ! '
So Answers:
R. Thomas Klinej
04/29/2002
ALAN S CARPEL
Deputy Sheriff
ALA1VS. CARPEL, ESQUIRE
Identification Number: 12048
1129 Spruce Street
Philadelphia, Pa 19107
(215) 238-7700
Consumer Portfolio Services Inc. :
16355 Laguna Canyon Road :
Irvine, California 92618 :
vs. :
Max G. Manwaring and :
Janet B. Manwaring :
146 West Park Street :
Carlisle, Pa 17013 :
COURT OF COati, ON PLEAS
OF CUMBERLAND COUNTY
NO. 02--1966
PRAECIPE TO DISCONTINUE WITHOUT PREJUDIC~
TO THE PROTHONOTARY:
Kindly discontinue
prejudice.
the above-captioned matter without
ALAN L, ESQUIRE
ATTOP~NEY FOR PLAINTIFF