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Home My WebLink About06-4345 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST ) CIVIL DIVISION, ARBITRATION COMPANY, t/a BB&T, ) AND STATUTORY APPEALS ONLY Plaintiff, VS. DUWAYNE G. YOUNG, Defendant. I hereby certify that the true and correct address of the Plaintiff is: 1 Piedmont Road Charleston, WV 25301 and the last known address of the Defendant is: 290 Liberty Drive Shippensburg PA 17257 Att4fney for Plaintiff NO.: 06-4345 Civil Term ISSUE NO. TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT CODE: FILED ON BEHALF OF: Plaintiff, Branch Banking and Trust Company, t/a BB&T COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. 400501 DAVIS DAVIS ATTORNEYS a professional corporation 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 412-344-0400 F:\DOCS\20843\060072\07031301.JUD.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, Plaintiff, vs. DUWAYNE G. YOUNG, Defendant CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.: 06-4345 Civil Term TO:PROTHONOTARY SIR: Please enter judgment by default against the above-named defendant, Duwayne G. Young, for failure to file an answer. Principal claimed in Complaint $16,977.19 with interest at the rate of 12.95% per annum from FIELD(30) through March 13, 2007 $ 1,397.43 Attorney's Fees $3,395.48 TOTAL $21,770.10 with continuing interest on the judgment amount of $21,770.10 at the rate of 6.00% per annum from March 13, 2007, plus costs. DAVIS DAVIS ATTORNEYS a professio corporation BY: JIV ed f. Davis Attorney for Plaintiff F:\DOCS\20843\060072\07031301.JUD.wpd AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATION 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 State, personally appeared Reed J. Davis, Attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance wi a.R.C.P. 237.1, as evidenced by the attached copy. Reed J. Davis Sworn to and subscribed before me day of March, 2007 vvt Q 0 ?16r .?D ,l ra.c ?lU Notary ?MMONWEALTH OF PENNSYLVANIA Notarial Seal i dy eevackoNotary Public wP•. egt" county My Qommission Bores Judy 7, 2008 M«mf?ar, nnaylvanla Association Of Notaries -. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST ) COMPANY, t/a BB&T, ) Plaintiff, ) vs. ) DUWAYNE G. YOUNG, ) Defendant. ) CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.: 06-4345 Civil Term TO: Duwayne G. Young 290 Liberty Drive Shippensburg PA 17257 DATE OF NOTICE: February 27, 2007 IMPORTANT NOTICE 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Court Administrator 4`h Floor, Cumberland Courthouse Carlisle, PA 17013 Telephone: 717/240-6200 DAVIS DAVIS ATTORNEYS BY: Attorney for Plaintiff 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 (412) 344-0400 a profess core "r n Re??d J. Dav s lad F:\DOCS\20843\060072\07022701.10D.wpd Ar ar n t 0 0 -J tom,- ? ., y'T .t? as IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, Plaintiff VS. DUWAYNE G. YOUNG, Defendant F:\DOC S\20843 \060072\06072101.com plaint ) CIVIL DIVISION NO. 6G - o4l,3*,? e;vtC`T? TYPE OF PLEADING: Complaint in Civil Action - Replevin FILED ON BEHALF OF: Plaintiff, BRANCH BANKING AND TRUST COMPANY, t/a BB&T COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis, Esquire Pa. I.D.#00501 DAVIS DAVIS ATTORNEYS a professional corporation 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 412-344-0400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t(a BB&T, CIVIL DIVISION NO. Plaintiff VS. DUWAYNE G. YOUNG, Defendant 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 after this complaint and notice are served, by entering a written appearance personally or by attorney and filing, in writing with the court, your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for 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 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 32 S. Bedford Street Carlisle, PA 17013 800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, Plaintiff VS. DUWAYNE G. YOUNG, Defendant. CIVIL DIVISION NO. COMPLAINT IN CIVIL ACTION - REPLEVIN AND NOW comes Branch Banking and Trust Company, t/a BB&T, by and through its counsel, Davis Davis Attorneys, a professional corporation, and makes this Complaint against the named Defendant and avers as follows: 1. Branch Banking and Trust Company, t/a BB&T, is a lending institution duly authorized to conduct business in the Commonwealth of Pennsylvania with one of its principal offices located at 1Piedmont Road, Charleston, WV 25301, hereinafter referred to as "Plaintiff." 2. Duwayne G. Young is an adult individual whose last known residence is 290 Liberty Drive, Shippensburg, PA 17257, hereinafter referred to as "Defendant." COUNTI 3. On or about November 15, 2005, Defendant purchased a 2001 Volvo, S80, Vehicle Identification No. YV 1TS94D611191549, and entered into a written Agreement for the payment of a portion of the purchase price. A true and correct copy of the aforesaid written agreement is marked Exhibit "A," attached hereto and made a part hereof. 4. The aforesaid written agreement was assigned for value to Plaintiff. 5. Plaintiff avers that the value of the aforesaid vehicle is $11,100.00 and that said vehicle is in the Defendant's possession, but its exact whereabouts is unknown. 6. Defendant has defaulted under the terms of the aforesaid written agreement by failing to make payments when due. 7. Plaintiff is entitled to immediate possession of the aforesaid vehicle and has demanded same from Defendant, who has failed and/or refused to deliver same to the Plaintiff. WHEREFORE, Plaintiff claims judgment for possession of one (1) 2001 Volvo, S80, Vehicle Identification No. YV ITS94D611191549, with interest, costs, attorney's fees and damages for the unjust retention of said vehicle. COUNT II 8. The averments contained in paragraphs 1 through 7 of Plaintiffs Complaint are incorporated herein by reference as if fully set forth at length herein. 9. The balance due and owing on the November 15, 2005, agreement is as follows: Principal $16,977.19 Attorneys Fees (20%) 3,395.48 TOTAL: 20 72.67 10. Under the terms of the aforesaid agreements, Plaintiff is entitled to interest at the rate of 12.95% per annum from July 24, 2006. WHEREFORE, Plaintiff demands judgment against the Defendant in the total sum of $20,372.67 with interest at the rate of 12.95% per annum from July 24, 2006, plus costs. BY: DAVIS DAVIS ATTORNEYS a professional corporation 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 (412) 344-0400 Attorney for Plaintiff (Page 1 of 19) 131 S) I MINIM V FUUNIC2 ww NMM WY.YYrmwNnY N1NM..0 i./.1 t 2001 YVIT5910611191519 ?Y.Yr Fffl WAITWf AwIWI MMifliMG Y Ywr. W..IMF/Y.w.niM MMnM.YC xn Aww.. INbsY TrYr F . T.YINa H .r.rwsYtlwbA..r WYw F Y TM YwY . N o M. .m..bwr ?..yr rr eYm. : mw w mNwMi Fm... w.tMYy wa ?. .YrY+F.rwPY.Y wW?`+r rYrbF.., rrr ?1"bti `:Fi ri.wepr 12.95 ? 6693.96 1 16391.90 !21092.16 A ? f` sa. . w y w r' w Yww KNCWWY M : . .. ar r r. w+YrrrrYmaaa.w. 66.YY?n.Yr.wwr. RWbIOFw MVw. 64 b.'. N.OIYwfIMNYFnWYNFM IS 6Ni.NYYYNaq.h. WYN µ•WbYN...OM •1?_v?_YrYFM.InplrbxYYlgYWtMFYy6Y6L. pry?t F4w.L.mnirm6wwYmrr M.Yn....M CM Y.wIi A W .YwY. Y M Mtl^+i4. 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YY/ w mrdYa tm F M wrb.rc ur b lbub PuWYUS YD^4o pKmM1a YdIWDOFYaYwwYE&NwWid YWIM4nNwV YAWIMI bUwwwylwaKmY.a ar NYma NMpEN&xrl4awl:lq'Iww MYw KBWr.wDpM KnnrWw.WwdMwXW wMdMndaLNE u:IN:KMnbwf. . a.er. wb.M.K wNWMarb.YM r K wbpY YIDID yN N wu NN:Q w Y MPYmY) M wML bm pu N w m w N W MYwpp.nrN g4wIwWYYm1 m MM w M4Y IYpa pleuMpu N yw/ rmNpHwmwa44 WY.wYVrKx IMaMwn mHMwMM.nwmN w .w.YnIYY. te?pwY• Ylb MHtwwYw I Ylr .bl M wHN.. n wry PxM Xxn p M i. x wr/ bw Kn b W u w pa Npna X M W b MY 14nw oM, w ^M' mVar p MpYwn. uml plMwnk44M NM .Mwp4, wH N+r rybp. YXYa I. M:I wY M yYY Nw Tla: b wy b Mwu. Ybwmvn MlY wXM MMYM wb4 W YY wNe4 NpumMMYlslXpu VERIFICATION I, Reed J. Davis, Esquire, state that I am not a party to the action but that at the request of the Plaintiff, and based upon knowledge, information, records, and documents supplied to me by the Plaintiff, the averments set forth in the foregoing Complaint in Civil Action -Replevin are true. A Verification executed by Plaintiff can be supplied at time of trial or upon request. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unworn falsification to authorities. Re J. Davis, quire ?9. t? _``? CrIl 'v b (/ COO , c _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, Plaintiff, vs. DUWAYNE G. YOUNG, CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.: 06-4345 Civil term ISSUE NO. TYPE OF PLEADING: Motion for Substitute Service Pursuant to Pa. R.C.P. No. 430 CODE: Defendant. FILED ON BEHALF OF: Plaintiff, Branch Banking and Trust Company, t/a BB&T COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. #00501 Davis Davis Attorneys a professional corporation 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 412-344-0400 F:\DOCS\20843\060072\0609180 1.SubSvc.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, CIVIL DIVISION, ARBITRATION, AND STATUTORY APPEALS ONLY Plaintiff, VS. DUWAYNE G. YOUNG, Defendant. NO.: 06-4345 Civil term MOTION FOR SUBSTITUTED SERVICE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 430 AND NOW, comes the Plaintiff, BRANCH BANKING AND TRUST COMPANY, t/a BB&T„ by and through their attorneys, Davis Davis Attorneys, a professional corporation, and hereby moves the Court for substitute service pursuant to Pennsylvania Rule of Civil Procedure 430 and in support thereof avers as follows: On or about July 31, 2006, Plaintiff filed a Complaint in Civil Action against the Defendant, Duwayne G. Young, hereinafter referred to as "Defendant" at the above-captioned term and number. 2. The last known address of the Defendant, is 290 Liberty Drive, Shippensburg PA 17257. 3. Pennsylvania Rule of Civil Procedure 430(a) permits original process to be served by having the sheriff hand a copy to the defendant or hand a copy to an adult member of the family or an adult person in charge of the residence of the defendant. 4. A true and correct copy of the Complaint in Civil Action was sent to the Sheriff of Cumberland County service on the Defendant, at the address of 290 Liberty Drive, Shippensburg PA 17257, to serve the same in accordance with Pennsylvania Rule of Civil Procedure 402. 5. A sheriffs return was received. A true and correct copy of said Sheriff s Return is marked Exhibit "A", attached hereto, and made a part hereof. 6. Plaintiff was advised by United States Postal Authorities that the Defendant, received mail at the address of 290 Liberty Drive, Shippensburg PA 17257 and that no change of address order is on file. A true and correct copy of said Postmaster letter is marked as Exhibit "B", attached hereto, and made a part hereof. 7. To date, the Plaintiff has been unable to effect service on the Defendant. WHEREFORE, Plaintiff respectfully requests this Court to enter an order authorizing service of the Complaint in Civil Action on the Defendant, by Plaintiffs counsel mailing by Certified Mail, Return Receipt Requested and by regular United States Mail using Post Office Form 3817, Certificate of Mailing, to the Defendant's last known address of 290 Liberty Drive, Shippensburg PA 17257. DAVIS DAVIS ATTORNEYS a professio orporation By: Re d J. Davis Attorney for the Plaintiff 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 (412) 344-0400 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04345 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRANCH BANKING AND TRUST CO VS YOUNG DUWAYNE G R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT YOUNG DUWAYNE G but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - REPLEVIN , the within named DEFENDANT , YOUNG DUWAYNE G NOT FOUND , as to 290 LIBERTY DRIVE SHIPPENSBURG, PA 17257 PEOPLE IN HOUSE ON DIFFERENT ATTEMPTS, BUT NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: So ans Docketing 18.00 Service 52.80 ` Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 85.80 DAVIS DAVIS 08/24/2006 Sworn and Subscribed to before me this day of , A. D. EXHIBIT 14 Sep 6, 2006 POSTMASTER Shippensburg PA 17257 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Duwavne G. Youne a/k/a Address: 290 Liberty Drive Shippensburg PA 17257 NOTE: The name and last known address are required for change of address information. The name, if known, and the post office box address post required for boxholder information. The following information is provided in accordance with 39 CFR 265.6 (d))(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manuel 352.44a and b. 1. Capacity of requester (e.g., process service, attorney, party representing himself): Paralegal 1 Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): NA 3. The names of all knowing parties to the litigation : Branch Banking and Trust Company v. Duwavne G. Young - 20843.060072 4. The court in which the case has been or will be heard: Common Pleas of Cumberland County, Pennsylvania. 5. The docket or other identifying number if one has been issued: 2006-04345 . 6. The capacity in which this individual is to be served (e.g. defendant or witness): defendant. WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNEC-F WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF- TO $10,000.00 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and must be used solely for service of legal process in connection with actual or prospective litigation. DAVIS DAVIS ATTORNEYS 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243-1478 Q? X z?0,1 FOR POST O FICE USE ONLY ADDRESS OR BOXHOLDER'S POSTMARK Receives mail at address given. Not known at address given. Moved, left no forwarding address. No such address. Forwarding order expired. Forwarding order address: EXHIBIT CURRENT NAME AND STREET ADDRESS PHYSICAL ADDRESS PLEASE *Any additional information to assist in locating addressees' w I - V-? AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me the undersigned authority, a Notary Public in and for said county and State, personally appeared Reed J. Davis, who being duly sworn according to law, deposes and says that, pursuant to Pennsylvania Rule of Civil Procedure 402, he was informed that the Sheriff of Allegheny County was unable to personally serve the Complaint upon the Defendant, at his last known address of 290 Liberty Drive, Shippensburg PA 17257 as evidenced on the Sheriffs Return. A true and correct copy of the Sheriffs Return is attached to the Motion as Exhibit "A". He further deposes and says that he was informed by the United States Post office that Defendant received mail at the address. A true and correct copy of the Post Office Letter is marked as "Exhibit "B" and also attached to the Motion. d .Davis Ree'd' Sworn to and subscribed before me ANthiC;* day of September, 2006 Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wrnbedy Sevacko, Notary Public Mt. Lebanon Tv p., Allegheny County My Commission E)ires July 7, 2008 Memtif- Pennsylvania Association Of Notaries ?,,. _.., , :. ` i+t= - ? . z? ? . r .` N `r Y - _.? ? , "? n ?? # { rry?' N A c1? .,? SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04345 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRANCH BANKING AND TRUST CO VS YOUNG DUWAYNE G R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT YOUNG DUWAYNE G but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - REPLEVIN NOT FOUND , as to the within named DEFENDANT 290 LIBERTY DRIVE SHIPPENSBURG, PA 17257 YOUNG DUWAYNE G PEOPLE IN HOUSE ON DIFFERENT ATTEMPTS, BUT NO ONE WOULD ANSWER THE DOOR. ?/. Sheriff's Costs: So ans --"?J Docketing 18.00 Service 52.80 ` Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 85.80 ? DAVIS DAVIS n Q?aS}u?- 08/24/2006 Sworn and Subscribed to before me this day of A. D. S E P 2 5 2006 7S , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, tta BB&T, Plaintiff, vs. DUWAYNE G. YOUNG, Defendant. CIVIL DIVISION, ARBITRATION, AND STATUTORY APPEALS ONLY NO.: 06-4345 Civil term ORDER OF COURT AND NOW, to-wit, this rl day of Q Gt , 2006, upon consideration of the Motion of the Plaintiff for substituted services, pursuant to Pennsylvania Rule of Civil Procedure 430, it is hereby, ORDERED, ADJUDGED AND DECREED that service of original process in this matter shall be made on the Defendant, DUWAYNE G. YOUNG, by Plaintiffs counsel mailing by Certified Mail, Return Receipt Requested and by regular United States Mail using Post Office Form 3817, Certificate of Mailing, to the Defendant's last known address of 290 Liberty Drive, Shippensburg PA 17257 with said service deemed to be effective upon the date of mailing. BY THE COURT: A? a? o.o r; f ^ } f 0,0 go IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a/ BB&T, Plaintiff vs CIVIL DIVISION ARBITRATION AND STATUTORY APPEALS ONLY NO.: 06-4345 Civil term ISSUE NUMBER: TYPE OF PLEADING: Affidavit of Service DUWAYNE G. YOUNG, Defendant CODE- FILED ON BEHALF OF: Plaintiff, Branch Banking and Trust Company, t/a BB&T COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis, Esquire Pa. I.D. #00501 DAVIS DAVIS ATTORNEYS a professional corporation Firm #063 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 (412) 344-0400 F :\DOCS\20843\060072\06101101.AffSvc.wpd AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY BEFORE ME, the undersigned authority, a notary public in and for said county and state, personally appeared Reed J. Davis who, being duly sworn according to law, deposes and says that in accordance with the Order of Court dated October 3, 2006, that he mailed a true and correct copy of the Complaint in Civil Action in the above-captioned case, by Certified Mail, Return Receipt Requested on the 10' day of October, 2006, to the following: Duwayne G. Young 290 Liberty Drive Shippensburg, PA 17257 He further deposes and says that he mailed said Complaint in Civil Action by regular U.S. Mail with the Post Office Form 3817 on October 10, 2006, to the same. A true and correct copy of the aforesaid Certified Mail Receipt and Post Office Form 3817 is marked as Exhibit "A", attached hereto and made a part hereof. Sworn to and subscribed before me-phis ,.' day of October, 2006. COMMONWEALTH OF PENNSYLVANIA Notarial Seal IGmberiy Sevacko, Notary Public Mt Lebanon Twp., Allegheny County My Commission E)ires July 7, 2008 Member, Pennsylvania Association Of Notaries Reed . avis U.S. Postal ServiceTM .Q MAILT. RECEIP CERTIFIED T -a (Domestic Only; No rl1 co " ate. Q F -n ? - $ r Postage C3 Certified Fee 0 C3 Return Reaept Fee -g (Endorsement Required) H O Ln Restricted Delivery Fee (Endorsement Required) _ M Total Postage & Fees ru pp nt-TO - DLIN)a n? G o? j J Y Sl t!d r- - SYree4 Apt. No.; )„o rha Drive- or PO Box No. Z010 LI - ------------ ------------- ---- ------- --------------------- PA 1fiZS? cq Stele. Z/PF4??'? b? r . , U.S. POSTAL SERVICE CERTIFICA'TE OF MAILING c L { MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURAN Received From: One piece of ordinary mail addressed to: _ Dvwa n? G. ; 2-01o 1 ?' 1 ?riy - -? PS Form 3817, January 2001 i OU003Z EXHIBIT A ra N tN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST ) CIVIL DIVISION, ARBITRATION COMPANY, t/a BB&T, ) AND STATUTORY APPEALS ONLY Plaintiff, VS. DUWAYNE G. YOUNG, Defendant NO.: 06-4345 Civil Term ISSUE NO. TYPE OF PLEADING: PRAECIPE FOR WRIT OF EXECUTION CODE: FILED ON BEHALF OF: Plaintiff, Branch Banking and Trust Company, t/a BB&T COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. #00501 DAVIS DAVIS ATTORNEYS a professional corporation 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 412-344-0400 F:000S\20843\060072\07050902.WritExec lad r a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST ) CIVIL DIVISION, ARBITRATION COMPANY t/a BB&T ) AND STATUTORY APPEALS ONLY Plaintiff, } vs. ) ) DUWAYNE G. YOUNG, } Defendant. ) NO.: 06-4345 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO:PROTHONOTARY Please issue a Writ of Execution, index it as a judgment in the judgment index, and direct it to the Sheriff of Cumberland County, against the Defendant, Duwayne G. Young, regarding the above-captioned case. saJZ t Amount Due $21,770.10! Interest from March 19, 2007 to May 9, 2007 $ 182.51 SUBTOTAL $21,952.61 [Costs to be added] $ TOTAL $ DAVIS DAVIS ATTORNEYS a pro ion corporation BY: Reed J. Davis Attorney for Plaintiff F:\DOCS\20843\060072\07050902.WritExec lad rp b ?v e• Z fl-4 -(A Sl? b f p cb 1 N -u` -... & C> d a ? `. ` ? t t r? C} ?a WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-4345 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BRANCH BANKING AND TRUST COMPANY, t/a BB&T Plaintiff (s) From DUWAYNE G. YOUNG, 290 LIBERTY DRIVE, SHIPPENSBURG, PA 17257. (1) You are directed to levy upon the property of the defendant (s)and to sell ALL OF HIS PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(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 $21,770.10 L.L. $.50 Interest FROM 3-19-07 TO 5-09-07 - $182.51 Atty's Comm % Due Prothy $2.00 Atty Paid $181.80 Other Costs Plaintiff Paid Date: 05-17-07 (Seal) REQUESTING PARTY: Name REED J. DAVIS, ESQUIRE Address: DAVIS DAVIS ATTORNEYS 393 VANADIUM ROAD, SUITE 300 PITTSBURGH, PA 15243-1478 ?!xo' 4 . 11 1 &44 ??44 - C R. Long, P no ry By: Deputy Attorney for: PLAINTIFF Telephone: 412-344-0400 Supreme Court ID No. 00501 , e t a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, Plaintiff, VS. CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.: 06-4345 Civil Term ISSUE NO. TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT DUWAYNE G. YOUNG, Defendant. I hereby certify that the true and correct address of the Plaintiff is: CODE: FILED ON BEHALF OF: Plaintiff, Branch Banking and Trust Company, t/a BB&T 1Piedmont Road Charleston, WV 25301 and the last known address of the Defendant is: 290 Liberty Drive Shippensburg, PA 17257 Z orney for Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. 400501 DAVIS DAVIS ATTORNEYS a professional corporation 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 412-344-0400 F:\DOC S\20 843\060072\07052101.JUD.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, Plaintiff, VS. DUWAYNE G. YOUNG, Defendant. TO: PROTHONOTARY SIR: CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.: 06-4345 Civil Term Please enter judgment by default against the above-named defendants, Duwayne G. Young, for possession of one (1) 2001 Volvo, S80, Vehicle Identification No. YV 1TS94D611191549. DAVIS DAVIS ATTORNEYS a profe corporation BY: eed J. Davis Attorney for Plaintiff .6 % J AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATION 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 State, personally appeared Reed J. Davis, Attorney for and authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed in accordance with Pa.R.C.P. 237. 1, as evidenced by the attached copy. Sworn to and subscribed before me the IZO-day of May, 2007 4uyj" Notary Publ c COMMONWEALTH OF PENNSYLVANIA Notarial Seal Nmbedy Sevacko, Notary PubliC Mt Lebanon Twp., Allegheny County My Commission Expires Duty 7, 2008 Member, ennsyivania Association Of Notaries .1 • 6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, Plaintiff, vs. DUWAYNE G. YOUNG, Defendant. TO: Duwayne G. Young 290 Liberty Drive Shippensburg PA 17257 DATE OF NOTICE: February 27, 2007 CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY NO.: 06-4345 Civil Term IMPORTANT NOTICE 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 ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Court Administrator 4"' [door, Cumberland Courthouse Carlisle, PA 17013 Telephone: 717/240-6200 DAVIS DAV?IS ATTORNEYS a profVco n BY: 1Zo6d Attorney for Plaintiff 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 (412) 344-0400 lad I-:ADOCS\20843\060072`07022701 . I OD.wpd w :: C `2 C' N +d -ar Mc .C' 0 -n MM y 0 TI 2 M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t(a BB&T, CIVIL DIVISION, ARBITRATION AND STATUTORY APPEALS ONLY Plaintiff, VS. DUWAYNE G. YOUNG, Defendant. NO.: 06-4345 Civil Term NOTICE OF ORDER. DECREE OR JUDGMENT TO: Duwayne G. Young 290 Liberty Drive Shippensburg, PA 17257 (X) Defendant You are hereby notif ed that an Order, Decree or Judgment was entered in the above captioned proceeding on 2UD'j (X) The judgment is as follows: possession of one (1) 2001 Volvo, S80, Vehicle Identification No. YV 1 TS94D611191549. F:\DOC S\20843\060072\07052101.JUD.wpd l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, Plaintiff CIVIL DIVISION NO.: 06-4345 Civil Term ISSUE NUMBER: VS. DUWAYNE G. YOUNG, Defendant TYPE OF PLEADING: Praecipe for Issuance of Writ of Possession CODE- FILED ON BEHALF OF: Plaintiff, Branch Banking and Trust Company, t/a BB&T COUNSEL OF RECORD FOR THIS PARTY: Reed J. Davis Pa. I.D. #00501 DAVIS DAVIS ATTORNEYS a professional corporation Firm #063 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 (412) 344-0400 F:\DOCS\20843\060072\07050901.WritPoss lad r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, t/a BB&T, Plaintiff VS. DUWAYNE G. YOUNG, Defendant CIVIL DIVISION NO.: 06-4345 Civil Term PRAECIPE FOR WRIT OF POSSESSION TO: Prothonotary SIR: Please issue a Writ of Possession directed to the Sheriff of Cumberland County, against the Defendant, DUWAYNE G. YOUNG, in the above captioned case, for possession of one (1) 2001 Volvo, S80, Vehicle Identification No. YV1TS94D611191549. Said Writ shall be conformed to join additional defendants and or any person in possession of one (1) 2001 Volvo, S80, Vehicle Identification No. YV1TS9413611191549. DAVIS DA ATTORNEYS a pro ion corporation Rped J: Davis Attorney for Plaintiff 393 Vanadium Road, Suite 300 Pittsburgh, PA 15243 (412) 344-0400 Vi 4ZI ?3h [ "Y _?? WWW ?r . V V) 441 -1,111, try op tl.:) ? W C1 C ? G V O w ^ ^ T -- wry. R r C*7 '?t?x y L co ; co r , ?k W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, T/A BB&T VS. No. 06-4345 Civil Term_ DUWAYNE G. YOUNG 290 LIBERTY DRIVE SHIPPENSBURG, PA 17257 Costs Attorney's $ 217.30 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) BRANCH BANKING AND TRUST COMPANY, T/A BB&T being: (Premises as follows): 2001 VOLVO, S80, VEHICLE IDENTIFICATION NO. YV1TS94D611191549 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. /s, / / ?, A 2 ? ?- 2 i 0;; 2 Ks R. Long, Prothonotary, Common Pleas Court of Cumberland C , PA Date JUNE 12, 2007 (Seal) a 1 1% 2of2 No 06-4345 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, T/A BB&T vs. DUWAYNE G. YOUNG 290 LIBERTY DRIVE SHIPPENSBURG, PA 17257 WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 217.30 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: REED J. DAVIS, ESQUIRE DAVIS DAVIS ATTORNEYS 393 VANADIUM ROAD, SUITE 300 PITTSBURGH, PA 15243-1478 412-344-0400 I.D. # 00501 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of , . I caused the within named , to have possession of the premises described with the appurtenances, and So Answers, Sworn and subscribed to before me this Day of , Sheriff By Prothonotary Deputy R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned Expired. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs 80.70 Docketing 18.00 69.30 Poundage 1.39 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 09/17/07 Mileage 38.40 Misc. Surcharge 20.00 Levy Post Pone Sale Certified Mail Postage .41 Garnishee ba Y 1 ? TOTAL 80.70 q So Answers; R. Thomas Kline, Sheriff t B y l iL z {LPL - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4345 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BRANCH BANKING AND TRUST COMPANY, t/a BB&T Plaintiff (s) From DUWAYNE G. YOUNG, 290 LIBERTY DRIVE, SHIPPENSBURG, PA 17257. (1) You are directed to levy upon the property of the defendant (s)and to sell ALL OF HIS PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attaclunent 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 $21,770.10 Interest FROM 3-19-07 TO 5-09-07 - $182.51 Atty's Comm % Atty Paid $181.80 Plaintiff Paid Date: 05-17-07 L.L. $.50 Due Prothy $2.00 Other Costs Curti . Long, Pro tary(Seal) By: Deputy REQUESTING PARTY: Name REED J. DAVIS, ESQUIRE Address: DAVIS DAVIS ATTORNEYS 393 VANADIUM ROAD, SUITE 300 PITTSBURGH, PA 15243-1478 Attorney for: PLAINTIFF Telephone: 412-344-0400 Supreme Court ID No. 00501 lot 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, T/A BB&T VS. DUWAYNE G. YOUNG 290 LIBERTY DRIVE SHIPPENSBURG, PA 17257 Attorney's Plaintiff's Prothonotary No. 06-4345 Civil Term- $217.30 $ 2.00 Costs COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) BRANCH BANKING AND TRUST COMPANY, T/A BB&T being: (Premises as follows): 2001 VOLVO, S80, VEHICLE IDENTIFICATION NO. YV1TS94D611191549 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. S R. Long, Prothonotary, Common Pleas Court of Cumberland ty, PA Date JUNE 12, 2007 (Seal) R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned Expired. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs 41.00 Docketing 18.00 109.00 Poundage 1.00 Advertising Law Library Prothonotary 2.00 Refunded to Atty on 09/17/07 Mileage Misc. Surcharge 20.00 Levy Post Pone Sale Certified Mail Postage Garnishee 17 TO TAL 41.00 So Answers; R. Thomas Kline, Sher B Q i y s t-, 4- J L 1? 2of2 No 06-4345 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRANCH BANKING AND TRUST COMPANY, T/A BB&T VS. DUWAYNE G. YOUNG 290 LIBERTY DRIVE SHIPPENSBURG, PA 17257 WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 217.30 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: REED J. DAVIS, ESQUIRE DAVIS DAVIS ATTORNEYS 393 VANADIUM ROAD, SUITE 300 PITTSBURGH, PA 15243-1478 412-344-0400 I.D. # 00501 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of I caused the within named to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of Prothonotary So Answers, Sheriff By Deputy