HomeMy WebLinkAbout06-4459GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
PA ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY
NO. NO C[Ucl+
Plaintiff,
V.
WILLIAM L DAVIS AND
LAURA L DAVIS,
Defendant(s).
COMPLAINT IN CIVIL ACTION
Filed on behalf of:
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
I? o- aa? y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR )
CREDIT COMPANY,
NO.
Plaintiff, )
V. )
WILLIAM L DAVIS AND )
LAURA L DAVIS, )
Defendant(s). )
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 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 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
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR )
CREDIT COMPANY, yyS 9
NO. -
Plaintiff )
V. )
WILLIAM L DAVIS AND LAURA L )
DAVIS, )
Defendant(s). )
COMPLAINT IN CIVIL ACTION
AND NOW, comes Plaintiff, FORD CREDIT t/d/b/a FORD MOTOR CREDIT COMPANY,
by and through its attomey,GREGG L. MORRIS, ESQUIRE and the law offices of PATENAUDE
& FELIX, A.P.C. and files the following Complaint in Civil Action, and in support thereof aver
as follows:
1. Plaintiff, FORD CREDIT t/d/b/a FORD MOTOR CREDIT COMPANY, is a
corporation with offices at 575 East Swedesford Road, Suite 100, Wayne, PA 19807.
2. Defendant is WILLIAM L DAVIS, an adult individual, who is believed to currently
reside at 671 SHIPPENSBURG RD, NEWVILLE, PA 17241.
3. Defendant is LAURA L DAVIS, an adult individual, who is believed to currently reside
at 671 SHIPPENSBURG RD, NEW VILLE, PA 17241.
4. On or about May 16, 2001, the aforesaid Defendant(s) entered into a written Automobile
Retail Installment Contract (hereinafter "Contract") to purchase a "Vehicle" from a dealer (Seller)
as more fully set forth in said Contract. A true and correct copy of the Contract is attached hereto,
marked as Plaintiffs Exhibit "1" and incorporated by reference.
5. "Seller" thereafter assigned the Contract to Plaintiff, FORD CREDIT.
6. Pursuant to the terms of the Contract, Defendant(s) were to make 61 payments of
$576.12 commencing on June 30, 2001.
The terms of the Contract provide for termination upon satisfaction by Defendant(s) of
all obligations provided thereunder.
8. Plaintiff avers that Defendant(s) defaulted under the Contract by failing to make
payments to Plaintiff as promised.
Due to Defendant's default under the Contract, Plaintiff exercised its rights to terminate
the Contract.
10. After calculating early termination charges due to Plaintiff, Plaintiff avers that a
deficiency balance of $9,921.92 is due from Defendant(s) as of October 22, 2004.
11. Plaintiff avers that such attorney's fees will amount to $3,274.23.
12. Despite repeated request, Defendant(s) have willfully failed and/or refused to pay the
aforesaid sum due.
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the
amount of $9,921.92, plus legal interest from the date of breach, reasonable attorney's fees in the
amount of $3,274.23 with continuing interest at the contract rate thereon from the date of Judgment
plus costs. The damages requested are less than the maximum amount for compulsory arbitration as
set by the Court.
Respectfully
713 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PENNSYLVANIA SRIPLE INTEREST VEHICLE i£EtA L
'06/16/2001
TTKLTYIENJ CONTRACT DATE
etRrnroa?sMawmawAadrmaj. '
INTERSTATE FORD:. INC.-
19C U&NUT BOTTOM- RD, =
PA'1
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-. 6RNND PBTx ._'° sti0i6?=TOW <73ni6-00
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Yost am Also lasa ASOwno< /awm OaAe
. '.' YOU MAY OBTAIN VEHICLE INSURANCE
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77 '. 'FROM A PERSON OF YOUR
CHOICE
. NOT REWWAD TO OBTAIN
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• •.. : CREDIT Lft CREW DISABYJFY AND
CREDIT
2. Doer PaymrO; ., OTHER OPI.IDWAL INSURANCE THIS
TMM_parly RoMb Aom"To Cls k ---_.._.___ s ` An..
,
" CONTRACT WILL NOT INCLUDE THEM
.
Cash Down PsymtlM._.?.,_-..?r.e.:...:;._?_:_._ S t t afl.Il(t UNILIMS YOU SIGN AND AGREE' O PAY
TraManaB_pgNj_- S13025,.00_ 5-33026.00 S KJA TNEPREANU6L
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To ?DFALER for DOC FEE" i 66-m• '
To 3T OF PA- for. ON LYRE 6E6 S' - NLrn '' Credt
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wnt0deyslas. Trr derp.rrpawnndw WSmord ori30.00 ohkAawr4 Alr. ? PV Tr onwrua AElairl Crepe
easarrA'Yrrrsat: YaumapNlparaslyblai 1b, rvdrwbsrppuahwed.
a 13 Toabe end tale
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tl sty atltlenmd tram Oft on leans' bwnas.n pr ?rmnl
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?pPaaewm..bmdra. am:lsau aona swrAlw yat wdr.al?.aae.:.: .'? ,_., -i QUESTIONS? . .t. ,
1s?s!lPOrrs w.m?!w+a!'malPar aW Paap<anwaom:,maraywr:!?!.t!amP.a ,?,
pmtri la ay.ow 1M,dnpa Yi{aarrldq<W oeusaxre.MYdwrMa . , ., ?,.. '
rlvu di-m mrr laaoa4os opq.tlpe?.' /'?+?^!YkiM wrw sy too aairasp teW Rr mNq .?
.wmmeo.rrtp.awe:'w.as.w:w.umsw'awrw ner..aaw raw:. . - ..... B. S
:.AW4110DIF"TION. DISCLOSURE ..'T - .. .
Any da9tt Maao}yosrt Min wdsnp atq sprg bYYOa ar4r_peftm.. - _ _
of sign tW contract In bhmk:
are entitled to an exact Dopy of the contract you sign.
f N to-Wtaet yt tl IIagal rights.. - / ?,-, ?• -
COPY
PLEASE CALLUS AT 100.727.7000
00-M 't'rl ,
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r Imrei mr Ir .ws'°raorrrW ms mwt
--?- _ - --- _ ADDITIONAL
A. Pollinates and Summary NO= Yw-muet'mel$ sO
paymsib when boy am due. Yoe may pmpey'yaur'debt et my
am wilow penes)': This Is a sable barest Conbam The
Saba] Mesa arpe you agree to pay WIN depart on Im r
payn ont pabeme. The amid fbance chugs may exceed the
dbdMW f:kw m Clasp ;,you mane your peynenb War ban
fie vdre hied daas.a in kee UM tha.edadtAw SMO M,; 11;
., Cmdew Mfr apply yw, *ink ft final fo Be, writ 4and •onpMd,
pmt of bus Fleas Cherpa rid than to Be Amount Financed. -
The CmdRDr arm to Fi ales Chaq by applying' to AV"
eaMWftps Race b UM unpab Amara FlSanad for the Wharf
ems tle tnpsN Annum.Fnrrad is wisaMNg BBe wade b
repSaesesed, YOU WW nail few Wright o r an I the contract
urlw Be, Grader apnea. -
IL SmmttylnoiaLL You give tie QeWaneseaasyladerestM.
1. T1r veNtle end W9anvmwrWas pd on ass velads: '
.. 2-Nmuwy ar poMSremivM Ortle, vabda;sa
.3. Nkauen ,vmmwnaandowAmemYwbfiaaeeoryw.
This wasae payment of all anatinb Yw ovis in 1Ne mnwad it
aisoaxvrerloiaaN&epr9smamaa Bea cahtrect
C. Wan of Vehicle- WARRANTEE Yw mid We cam of
Be, wade andpbey at lewd M uenp k You may not ad or red
ins ,,hid , and yw meat asap k No Iran the deims of Others.
You WE rapt use W pamat the use odfatho wNtls wh de of am _
or Moudco.-'
United
vahw the pdw aaenl the Ch dlorfdo sehhk:b Is wdftn of a typo normally Used for prsenel use and Use Cnedda. W
Nan whlWS mnufam or. arW ' a wlden wamnty or
- arebm cohered owrinp tln whom WIMM fe days diem Se
did Of cob oattrae4 ym pat iseI" wrensa d
the WhICkL OUMWb& YOU undwatand we epee tat tlarW
are no web "led warranties.
0. Innranes: Yw mad kwon ymesesand•#0 CmdiW eybst
bxe or scrape to the whk7a. The C*Itdr mest approve Be,
type eM etnanmtdkntnanaa. Nun CMWM*blWm screw M
kaumna a SWANS Conbeds, the Ccedna WW subbed se,
mead from Met you ohs. Whether W not the whtda Is
Inured, you mE pay for N s N b Nat, •damav.4 W
dsetraYarL - r
If a charge for vehkke kwaawa Is awn on tin tort, the
Cradbr Ml try to bey the roMMOSS dadwd fa ae lam ehoWn.
The Creditor is not sea, Bough, V he and do'co. N Bides
coveryse cast mane ton the an ouna shown for h osawsm, the
Cmdlor may buy Bern for a SMrbr Will a he nay plus you '
own for 00 Smoum f1aAIL B he nano] prey eery lseasea, he '
Md plus you amdl forth stmt crow. The anacR will be made
to the hid pe)wrm dse.
E Las ChWI W Yw WS new to pay a he charge on Me
puma of SWk pmamrd was hers then an days ha. ih
ahefq b shown w Be, frurL Acceptance arm ab prym ad does
not setae Yee deauk or new Not you can keep IirNnp .
PWOr dA,VM em &W The CradNr may ab the sees set
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tom Mtles oanbacL SSemarrydea?6
AGREEIAENTS - - - -
F. Def.] ,Yw'wfllbsindsfta", ?: .. a-:
1. Yw so not make a paymeR when sh"'a,- .
2. Yw pew Glee artabadMl lnfmmlion'a yaa.aedk:._'
appfintlon min" to this aantracC a- ... .,
3., Y n u r "halo I n n pal bysr y ]oral, eat, ar federa_ o':
. , auN erd a rat pmrii*and uncaidmwl- - ?.
rebm doyou; %. :.- ., .. .n: W.
4. You-flk a banluprcy pafpon pr oils is flied alaal y w-.or
S. You do not kW aft uther-pmirlis, lfi:Pb ONdm .= .,
If you sm In ddoWL to Cmtlkor may revues yW b pry m use
- Ike-mpaid Amount l"Ina a 1, Bw awned and apdd'prt'bf tile';
Faanm Charge NOW DOW wmumb dm adm Has armed.
Ns'may rapoawa (tab Iank)' de yehlclo. oW. He Miky'sio,
tatcei goods blind N .a w Be 4" when mpaeeewd and
hddthenfayw.. - -' --
shl ;1lrowdedehWanWet,inn(buyb9 yvp e. Itr.Mla,
a say tlrt you may edam (buy back) the ,v WeNwclly . It wLa
ia
dtow to Wanted rieedse a Odessa. vuu .cloy !ede6m Via:
ywyoudo4svsyttmdwMmeaeswmQedtd.:svAl mPo StWWb&odr•* Qseyd tt,
md..n '. " .
The c]Mka WR me Ilae?nMOMY fun tin Salt. IMS NW Shamed,
expenses, to pay Be wmaunt SWI owed. on WS,,mmma!
.. Expenses ON M s dad ma dl.a hiMnj to iaeks ye, rededs..
held n for sale, Bret ayl'n'pe, es Prnwitl'* tw, aflvwld
•eiearaes: Lawyerw fies ird%epel me4 pefr fta W hew sm;
slowed, too. The Cedror Mt.pay'yw cry MMW •a8 (s
Cmd It
labYw y wd do not not py,msy.nia n hawa awkq whop Ater Be, eQUWOI B Sal
go Cma k.. idb d Weeks eke m*
"Bic Credttor?eY IfiBNS you irrbke9t' at claw Idpheawfrrl rals•
un0 Yw pay'
Q -snarsl: To canted Fad Motor Cmdl'Canepany Shout Bai
wcamK Call 1{SOS) 727-7000. be, Iw of Panaylwus applies
to this oaeed. If Na law does not elm M aUthe apmrnerna'
M this conlmct,-the ones, aiei are not slowed WIN be void. The
- '
and ofthiianmd wall DWI be &W.
r
atmRaNrr .
To aesa am Seder to spa lye vends described on the immorNamded to the Buyer. on onakw A pananwhostpaa bdwas s
"GAnvW guarantees the ps mra or 00 waled,. Thin rowne that if Be Buyer tab p pay any deny Iliit lsbwfd?co ana
wntma aedi "Who dgra me puMnb wR pay kwonn awed Each prawn Who rpra balm spores that he wall be mN's'fu Bic
wrole arMM Quad eon k and a mane cow panda also allies kale GUreray. He ado slaves to w table evrtY lye Cmdna dales
prr'a hen a h toBOMnp: (a) paws des BuyW iron tree a PaY-ern u mom prynere..a (b) phe,s s rNeisi N idl:a F Purl e
ey ate ode r GureMa. a (a) mwwe any sewrtly. Ewh Guerenar Wo steae that he has naalwd a cornplellE copy of no
oohed and this GamMty at to tlme of slip".
Gmrrder AddrM •' r.. - .r'
Guarror Address '.
VERIFICATION
The undersigned is an authorized agent of the Plaintiff and verifies that the facts and
statements made herein are true and correct based upon my knowledge, information and
belief, and are based upon and have been obtained from a review of the facts and
information contained in the business records of the Plaintiff supplied to us by Plaintiff.
Counsel has signed the verification as a matter of time and convenience. The verification
of the party will be provided if requested. The statements are made subject to the
penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities.
Date: July 20, 2006
Pa aude & Felix, A.P.C.
13 E. Main Street
Carnegie, PA 15106
(412) 429-7675
? ? ? ?
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GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
PA ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff,
NO. 06-4459-CIVIL-TERM
V.
WILLIAM L DAVIS AND
LAURA L DAVIS,
Defendant(s).
PRAECIPE FOR
DEFAULT JUDGMENT
Filed on behalf of:
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
NO. 06-4459-CIVIL-TERM
Plaintiff
V.
WILLIAM L DAVIS AND
LAURA L DAVIS,
Defendant(s)
PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT
TO: PROTHONOTARY
Please enter a judgment against the Defendant(s), above named., for failure to file an Answer to
Plaintiffs complaint.
Amount claimed in Complaint $9,921.92
Interest from October 22, 2004 $78.14
Attorney's fees $3,274.23
TOTAL $13,274.29
With continuing interest on the principal amount of $13,274.29, with interest at the legal rate,
plus costs of suit.
I hereby certify that a written notice of intention to file this praecipe was mailed to the
Defendant(s) and Defendant(s) counsel (if known), after the default had occured and at least ten (10)
days prior to the date of the filing of this praecipe. A copy of the Notice is attached.
.C.
k1REQG L. MORRIS, ESQUIRE
Pa enaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
V.
WILLIAM L DAVIS AND
LAURA L DAVIS,
Defendant(s)
NO. 06-4459-CIVIL-TERM
PLAINTIFF'S AFFIDAVIT OF NON-MILITARY SERVICE AND MAILING OF
NOTICE PURSUANT TO PA.R.C.P. 1037(b)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
Before me, the undersigned authority, a Notary Public in and for said County and State,
Personally appeared Gregg L. Morris, Attorney for and authorized representative of Plaintiff, who being
duly sworn according to law, deposes and states that the Defendant(s), WILLIAM L DAVIS AND
LAURA L DAVIS , is not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that Notice of Intent to take Default Judgment was
mailed in accordance with Pa.R.C.P. 237. 1, as evidenced by the attached copy.
Patenaytre A Felix,,XP.C.
By:
L.. S, ESQUIRE
e & Feh , A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
Sworn to d subscri ed before me
t day of 206k,
Nary Public
I,, L i_ .?i
P4-.1arv P itAic
CARNEGIL BOROUGH
ALLEGHENY COUNTY
My Commission Expires Feb 11, 2008
GREGG L. MORRIS, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
PA ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY
Plaintiff,
NO. 06-4459-CIVIL-TERM
V.
WILLIAM L DAVIS AND
LAURA L DAVIS,
Defendant(s).
IMPORTANT NOTICE
Filed on behalf of:
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
NO. 06-4459-CIVIL-TERM
Plaintiff
V.
WILLIAM L DAVIS AND
LAURA L DAVIS,
Defendant(s)
To: WILLIAM L DAVIS
671 SHIPPENSBURG RD
NEWVILLE, PA 17241
LAURA L DAVIS
671 SHIPPENSBURG RD
NEWVILLE, PA 17241
Date of Notice: August 29, 2006
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PEROSONALLY 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 JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A 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 S. BEDFORD STREET
CARLISLE, PA 17013 n
717-249-3166 / I
ate de & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
I, GREGG L. MORRIS, attorney for Plaintiff, FORD CREDIT t/d/b/a FORD
MOTOR CREDIT COMPANY, herby certify that a true and correct copy of the
foregoing document was served this day by US First Class Mail, postage prepaid upon
the following:
WILLIAM L DAVIS LAURA DAVIS
671 SHIPPENSBURG RD 671 SHI ENSBUR RD
NEWVILLE, PA 17241 NEWV E, P 41
Date: August 29, 2006
& Felix, A.P.C.
for Plaintiff
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
GREGG L. MoRRIs, ESQ.
PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
(412) 429-7675
FACSIMILE (412) 429-7679
PA ID#69006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
NO. 06-4459-CIVIL-TERM
Plaintiff,
V.
WILLIAM L DAVIS AND
LAURA L DAVIS,
Defendant(s).
NOTICE OF ORDER,
DECREE OR JUDGMENT
Filed on behalf of:
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
Plaintiff
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 East Main Street
Carnegie, PA 15106
(412) 429-7675
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT t/d/b/a FORD MOTOR
CREDIT COMPANY,
NO. 06-4459-CIVIL-TERM
Plaintiff,
V.
WILLIAM L DAVIS AND
LAURA L DAVIS,
Defendant(s).
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: ( ) Plaintiff ( X ) Defendant ( ) Garnishee ( ) Additional Defendant
You are h "y notified that the following Order, Decree, or Judgment has been entered
against you on _10o4:-
1 ( ) Decree Nisi in Equity
( ) Final Decree in Equity
( X) Judgment of ( ) Confession ( ) Verdict ( ) Court Order
( X) Default ( ) Non-suit
( ) Non-Pros ( ) Arbitration Award
( X) Judgment in the amount of $13,274.29, plus cost.
( ) District Justice Transcript of Judgment in the amount of $ ,
plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle operator's license wil be
suspended by the Department of Transportatio
Proth not
By
Deputy
If you have questions concerning the above, please contact:
Name of Attorney: GREGG L. MORRIS, ESQUIRE
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-04459 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FORD CREDIT ET AL
VS
DAVIS WILLIAM L ET AL
JASON VIORAL , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
DAVIS WILLIAM L the
DEFENDANT , at 1759:00 HOURS, on the 7th day of August 2006
at 671 SHIPPENSBUR(l ROAT)
NEWVILLE, PA 17241
WILLIAM DAVIS
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: So Answers:
Docketing 18.00
Service 13.20
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
41.20; 08/08/2006
9_a5-.0` PATENAUDE & FELIX
Sworn and Sub 'b d t
sci e o By:
before me this day epu y Sheriff
of A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-04459 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FORD CREDIT ET AL
VS
DAVIS WILLIAM L ET AL
JASON VIORAL , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
DAVIS LAURA L the
DEFENDANT at 1759:00 HOURS, on the 7th day of August 2006
at 671 SHIPPENSBURG ROAD
NEWVILLE, PA 17241
by handing to
WILLIAM DAVIS, HUSBAND
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: So Answers:
Docketing
Service 6.00
00
.
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
16.00,/ 08/08/2006
4" A ?? pG PATENAUDE & FELIX
Sworn and Subscibed to By:
before me this day De u Sheriff
of A.D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/D/B/A FORD MOTOR CREDIT
COMPANY
Plaintiff
V.
WILLIAM L DAVIS and LAURA L DAVIS
Defendant(s)
MEMBERS FIRST CREDIT UNION
Garnishee
NO. 06-4459-CIVIL-
TERM
PRAECIPE FOR WRIT OF
EXECUTION
Filed on behalf of:
FORD CREDIT T/D/B/A FORD
MOTOR CREDIT COMPANY
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_134 Prep Writ of Exe
P&F File No. 2800.2264
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/DB/A FORD MOTOR CREDIT
COMPANY
Plaintiff
V.
WILLIAM L DAVIS and LAURA L DAVIS
Defendant(s)
MEMBERS FIRST CREDIT UNION
Garnishee
NO. 06-4459-CIVIL-
TERM
PRAECIPE FOR WRIT OF EXECUTION
To The Prothonotary:
Issue writ of execution in the above matter,
(1) directed to the Sheriff of Cumberland County;
(2) against, WILLIAM L DAVIS and LAURA L DAVIS Defendant(s);
(3) against, MEMBERS FIRST CREDIT UNION, Garnishee;
(4) and index this writ
(a) against, Defendant(s) WILLIAM L DAVIS and LAURA L DAVIS, Defendant(s); and
(b) against MEMBERS FIRST CREDIT UNION, Garnishee;
as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows:
(5) Amount due
Interest from September 13, 2006
At 5.00 % per annum
(Costs to be added)
$13,274.29
$1,718.56
PA_134 Prcp Writ of Exe
P&F File No. 2800.2264
O
T THE F'-r,T-4!l{0TA9Y
2009.JU 22 P1"i 1: 1Ii
CUP, ") iJN i
$a4.5o Po ATrY
U.00 PO ArrY
• 50 LL
?,* 3(o9aa
E? ?83l3
Ori+ &f 4 ezssoed
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-4459 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FORD CREDIT t/d/b/a FORD MOTOR CREDIT
COMPANY, Plaintiff (s)
From WILLIAM L. DAVIS and LAURA L. DAVIS, 671 Shippensburg Road, Newville, PA 17241
(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
GARNISHEE(S) as follows:
MEMBERS FIRST CREDIT UNION, 1711 Spring Rd, Carlisle, PA 17013
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 $13,274.29
L.L. $.50
Interest from 9/13/06 at 5.00% per annum - $1,718.56
Atty's Comm % Due Prothy $2.00
Atty Paid $148.70
Plaintiff Paid
Other Costs to be added
Date: 7/22/09
(Seal)
REQUESTING PARTY:
Name GREGG L. MORRIS, ESQUIRE
Address: PATENAUDE & FELIX, APC
213 E. MAIN STREET
CARNEGIE, PA 15106
Attorney for: PLAINTIFF
Telephone: 412429-7675
Supreme Court ID No. 69006
Deputy
RECEIVED
AUG 0 6 2009
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/DB/A FORD MOTOR CREDIT
COMPANY
Plaintiff
NO. 06-4459-CIVIL-
TERM
V.
WILLIAM L DAVIS and LAURA L DAVIS
Defendant(s)
MEMBERS FIRST CREDIT UNION
Garnishee
INTERROGATORIES IN
ATTACHMENT EXECUTION
Filed on behalf of:
FORD CREDIT T/DB/A FORD
MOTOR CREDIT COMPANY
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_139 Interogs Attch Exe P&F File No. 2800.2264
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/DB/A FORD MOTOR CREDIT
COMPANY
Plaintiff
NO. 06-4459-CIVIL-
TERM
V.
WILLIAM L DAVIS and LAURA L DAVIS
Defendant(s)
MEMBERS FIRST CREDIT UNION
Garnishee
OFFICES OF PATENAUDE & FELIX
BY: GREGG MORRIS, ESQUIRE
213 East Main St
Carnegie PA 15106
858-244-7675
You are hereby notified to
plead to the enclosed
Interrogatories within 20
days from the date of
hereof or a default
judgment may be entered
against you.
Gregg Morris, Esquire
Attorney for Plaintiff
INTERROGATORIES IN ATTACHMENT EXECUTION
You are required to answer the following interrogatories about Defendant(s) whose address is 671
SHIPPENSBURG RD . NEWVILLE PA 17241. You must file with the Court answers to the following
interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default
judgment being entered against you. A copy of said answers must be served on the undersigned. If your
answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of
the subject property.
PA_139 Interogs Attch Exe P&F File No. 2800.2264
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 defendant(s) on any negotiable or other written
instrument, or did defendant(s) claim that you owed them any money or were you liable to them
for any reason? If yes, please specify as set forth herein.
Na
2. At the time you were served, or at any subsequent time, was there in your
possession, custody or control, or in joint possession, custody or control of yourself or others,
any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and
describe the property.
3. At the time you were served, or at any subsequent time, did you hold legal title to
any property or any nature owned solely or in part by the Defendant(s)? If yes please list and
describe the property. K
4. At the time you were served, or at any subsequent time, did you hold as fiduciary
any property in which the Defendant(s) had an interest? If yes, please list and describe the
property. ?6
PA_1 39 Interogs Attch Exe P&F File No. 2800.2264
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 directions or consent? If
yes, what was the consideration therefore?
N
6. At any time after you were served, did you pay, transfer, or deliver any money or
property to the Defendant(s) or to any person or place pursuant to their direction, or otherwise
discharge any claim of the Defendant(s) against you.
NO
7. 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 funds are
deposited electroncially 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 and the entity electronically depositing those funds on a recurring basis.
W6
PA_ 13 9 Interogs Attch Exe P&F File No. 2800.2264
8. If you are a bank or other financial insitution, 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 42 Pa.C.S. § 8123? If so, indentify each account..
ma/ ?LL ee?
Respectfully submitted:
Patenaude & Felix, A.P.C.
Date: July 01, 2009
Gregg L. Morris, Esquire
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA-139 Interogs Attch Exe P&F File No. 2800.2264
SERVE
y 4 f ,7
sfRVE
S
KI 0
MEMBERS 1St
FEDERAL CREDIT UNION
August 6, 2009
Name: Laura L. Davis and
William L. Davis (Deceased 01/28/07)
Address: 671 Shippensburg Road
Newville, PA 17241
Account Number: XXX139
Name on Account:
Signer:
Business Savings:
Business Checking:
Account Number: XXX357
Name on Account:
Savings:
Checking:
Alliance Maintenance
Laura Lee Davis
$0.00
$10.89
$1( 0.89) Processing Fee
$0.00
Rebecca A. Horst
Laura L. Davis (Joint)
Holly J. Holbrook (Joint)
$25.00
$1,100.31
$300.00 Statutory Exemption was not taken out.
- jax-'14- I
Tania S Young
Deposit Operations A lyst
5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • wwwmemberslst.org
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is Tania S. Young
(Name)
Deposit Operations Analyst of Members 1st Federal Credit Union
(Title)
(Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
'?'JDMA -
(SIGNAT RE)
^;C r -
L'09 ' `'?
Sheriffs Office of Cumberland County
R Thomas Kline
{?i !- r
Sheri F THE n
??y?,ttitr Df ?un?brrl??D
Ronny R Anderson c r? r.
Chief Deputy s t;3~ Lnn. L!, 3 a'i a utj
L J? n J
Jody S Smith
Civil Process Sergeant OFFICE -1 ERIFF
Edward L Schorpp
Solicitor
Ford Credit t/d/b/a Ford Motor Credit Company
Case Number
vs.
Laura L Davis 2006-4459
SHERIFF'S RETURN OF SERVICE
08/06/2009 03:38 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 6,
2009 at 1540 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Laura L. Davis, and William L. Davis, in the hands, possession, or
control of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle,
Cumberland County, Pennsylvania 17013, by handing to Kristal M. Luckey, Member Service
Representative 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 08-07-09 to Laura L. Davis at 671
Shippensburg Road, Newville, PA 17241, and to William L. Davis at 671 Shippensburg Road, Newville,
PA 17241.
So Answers,
R. Thomas Kline, Sheriff
By
4geeppulty'Shetiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/DB/A FORD MOTOR CREDIT
COMPANY
Plaintiff
NO. 06-4459-CIVIL-
TERM
V.
WILLIAM L DAVIS and LAURA L DAVIS
Defendant(s)
MEMBERS FIRST CREDIT UNION
Garnishee
PRAECIPE FOR JUDGMENT
UPON ANSWERS TO
INTERROGATORIES
Filed on behalf of:
FORD CREDIT T/DB/A FORD
MOTOR CREDIT COMPANY
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. 469006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_I 17A Prep DefJg Bank P&F File No. 2800.2264
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/D/B/A FORD MOTOR CREDIT
COMPANY
Plaintiff
V.
WILLIAM L DAVIS and LAURA L DAVIS
Defendant(s)
MEMBERS FIRST CREDIT UNION
Garnishee
NO. 06-4459-CIVIL-
TERM
PLAINTIFF'S PRAECIPE FOR JUDGMENT
UPON ANSWERS TO INTERROGATORIES
TO: PROTHONOTARY arm'zz we *k*<tc
Please enter a judgment against the ?t, above named, for failure to file an Answer
to Plaintiffs complaint.
Amount claimed in Complaint $1,100.31
Interest from August 11, 2004 $0.00
Exemption -$300.00
Less payments received $0.00
Attorney's fees $0.00
TOTAL $800.31
With continuing interest on the principal amount of $800.31, with interest at the legal
rate, plus costs of suit.
I hereby certify that a written notice of intention to file this praecipe was mailed to the
defendants and defendants' counsel (if known), after the default had occurred and at least ten
(10) days prior to the date of the filing of this praecipe. A copy of the Notic is attached.
Respectfully sub itt d:
Patenaude & Felix, /..P.C.
Date: December 10, 2009
Gregg M is, squire
213 E n Str t
(41?j429 P 6 ? 106
PA_117A Prcp Def Jg Bank P&F File No. 2800.2264
RECEIVED
AUG 1 2 2009
RECEIVED
AUG 0 6 2009
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/DB/A FORD MOTOR CREDIT
COMPANY
Plaintiff
NO. 06-4459-CIVIL-
TERM
V.
WILLIAM L DAVIS and LAURA L DAVIS
Defendant(s)
MEMBERS FIRST CREDIT UNION
Garnishee
CD
INTERROGATORIES IN
ATTACHMENT EXECUTION
Filed on behalf of:
FORD CREDIT T/DB/A FORD
MOTOR CREDIT COMPANY
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_139Interogs Attch Exe P&F File No. 2800.2264
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/DB/A FORD MOTOR CREDIT )
COMPANY )
NO. 06-4459-CIVIL-
Plaintiff ) TERM
V. )
WILLIAM L DAVIS and LAURA L DAVIS )
Defendant(s) }
}
MEMBERS FIRST CREDIT UNION )
Garnishee )
OFFICES OF PATENAUDE & FELIX You are hereby notified to
BY: GREGG MORRIS, ESQUIRE plead to the enclosed
213 East Main St Interrogatories within 20
Carnegie PA 15106 days from the date of
858-244-7675 hereof or a default
judgment may be entered
against you.
Gregg Morris, Esquire
Attorney for Plaintiff
INTERROGATORIES IN ATTACBMNT EXECUTION
You are required to answer the following interrogatories about Defendant(s) whose address is 671
SHIPPENSBURG RD, NEWVILLE PA 17241. You must file with the Court answers to the following
interrogatories within twenty (20) days after service upon you. Failure to do so may result in a default
judgment being entered against you. A copy of said answers must be served on the undersigned. If your
answer to any of the following interrogatories is affirmative, specify the amount, value and/or nature of
the subject property.
PA_1391nterogs Anch Exe P&F File No. 2800.2264
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 defendant(s) on any negotiable or other written
instrument, or did defendant(s) claim that you owed them any money or were you liable to them
for any reason? If yes, please specify as set forth herein.
N0
2. At the time you,were served, or at any subsequent time, was there in your
possession, custody or control, or in joint possession, custody or control of yourself or others,
any property of any nature owned solely or in party by the Defendant(s)? If yes, please list and
describe the property.
H 0
3. At the time you were served, or at any subsequent time, did you hold legal title to
any property or any nature owned solely or in part by the Defendant(s)? If yes please list and
describe the property.
4. At the time you were served, or at any subsequent time, did you hold as fiduciary
any property in which the Defendant(s) had an interest? If yes, please list and describe the
property. M
PA- 139 Interogs Attch Face P&F File No. 2800.2264
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 directions or consent? If
yes, what was the consideration therefore?
f
0
6. At any time after you were served, did you pay, transfer, or deliver any money or
property to the Defendant(s) or to any person or place pursuant to their direction, or otherwise
discharge any claim of the Defendant(s) against you.
N0
7. 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 funds are
deposited electroncially 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 and the entity electronically depositing those funds on a recurring basis.
N 6
PA_139 Interogs Attch Exe P&F File No. 2800.2264
8. If you are a bank or other financial insitution, 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 42 Pa.C.S. § 8123? If so, indentify each account..
MO L, w±A?
l
Date: July 01, 2009
Respectfully submitted:
Patenaude & Felix, A.P.C.
Gregg L. Morris, Esquire
21 E. Main Street
(Idmegie, PA 15106
(412) 429-7675
PA_l39 Interogs And Exe P&F File No. 2800.2264
A
MEMBERS 1St
FEDERAL CREDIT UNION
August 6, 2009
Name: Laura L. Davis and
William L. Davis (Deceased 01/28/07)
Address: 671 Shippensburg Road
Newville, PA 17241
Account Number: XXX139
Name on Account:
Signer:
Business Savings:
Business Checking:
Account Number: XXX357
Name on Account:
Savings:
Checking:
Alliance Maintenance
Laura Lee Davis
$0.00
$10.89
$1( 0.89) Processing Fee
$0.00
Rebecca A. Horst
Laura L. Davis (Joint)
Holly J. Holbrook (Joint)
$25.00
$1,100.31
$300.00 Statutory Exemption was not taken out.
Jul
Tania S Young
Deposit Operations A lyst
4A'
5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • wwwmemberslst.org
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is_
(Name)
Deposit Operations Analyst of Members 1st Federal Credit Union
(Title) (Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
Tania S. Young
(SIGNAT RE) 4 T
FL(,.(1...,(i"'r ivy
-, ,DIARY
2f011 DiC 17 PM 14:37
IJiV t 1
+,+.0o pf--' ATTY
C,,* 3'7d loaf
2T* a?tcorn
?h,e?, ?i led
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/D/B/A FORD MOTOR CREDIT
COMPANY
Plaintiff
V.
WILLIAM L DAVIS and LAURA L DAVIS
Defendant(s)
MEMBERS FIRST CREDIT UNION
Garnishee
NO. 06-4459-CIVIL-
TERM
NOTICE OF ORDER, DECREE
OR JUDGMENT
Filed on behalf of:
FORD CREDIT T/D/B/A FORD
MOTOR CREDIT COMPANY
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_l21 A Ntc Jgmt Bank P&F File No. 2800.2264
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD CREDIT T/D/B/A FORD MOTOR CREDIT
COMPANY
Plaintiff
V.
WILLIAM L DAVIS and LAURA L DAVIS
Defendant(s)
MEMBERS FIRST CREDIT UNION
Garnishee
NO. 06-4459-CIVIL-
TERM
NOTICE OF ORDER, DECREE OR JUDGMENT
TO:( )Plaintiff ( )Defendant ( X )Garnishee ( )Additional Defendant
You are hereby notified that the following Order, Decree, or Judgment has been entered
against you on
( ) Decree Nisi in Equity
( ) Final Decree in Equity
( X ) Judgment on ( ) Confession ( ) Verdict ( ) Court Order
( ) Default ( ) Non-suit ( X) Interrogatories
( ) Non-Pros ( ) Arbitration Award
( X ) Judgment in the amount of $800.31, plus costs.
( ) District Justice Transcript of Judgment in the amount of $ ,
plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be
suspended by the Department of Transportation.
Prothonotary
By s
Deputy ?J fC?
If you have questions concerning the above, please Contact:
Name of Attorney: GREGG MORRIS, Esquire
213 East Main St
Carnegie PA 15106
(412)-429-7675
PA_121A Nte Jgmt Bank P&F File No. 2800.2264
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff p* FLED-i ?c
a ?t1tt116? 47I 711 U?, 'rd }Y P,: Ey ? ,M?\1 1"i :,
Jody S Smith ' J
Chief Deputy 7010 MAR 31 PM I2: 3
Edward L Schorpp
Solicitor , CUM ?JAN
PENNSSYLVA I`4%
Ford Credit t/d/b/a Ford Motor Credit Company Case Number
vs.
Laura L Davis (et al.) 2006-4459
SHERIFF'S RETURN OF SERVICE
08/06/2009 03:38 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 6,
2009 at 1540 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Laura L. Davis, and William L. Davis, in the hands, possession, or
control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle,
Cumberland County, Pennsylvania 17013, by handing to Kristal M. Luckey, Member Service
Representative 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 08-07-09 to Laura L. Davis at 671
Shippensburg Road, Newville, PA 17241, and to William L. Davis at 671 Shippensburg Road, Newville,
PA 17241.
03/30/2010 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: $97.70
March 30, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
B
S aron R. Lantz
co pd. Co.
6-0 t- Fd
&*75`/r3
a39 q
+.r; counfy5uitn $hESrrtf.
WRIT OF EXECUTION and/or ATTACHMENT
• w'
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-4459 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FORD CREDIT t/d/b/a FORD MOTOR CREDIT
COMPANY, Plaintiff (s)
From WILLIAM L. DAVIS and LAURA L. DAVIS, 671 Shippensburg Road, Newville, PA 17241
(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
GARNISHEE(S) as follows:
MEMBERS FIRST CREDIT UNION, 1711 Spring Rd, Carlisle, PA 17013
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 $13,274.29
L.L. $.50
Interest from 9/13/06 at 5.00% per annum -- $1,718.56
Atty's Comm % Due Prothy $2.00
Atty Paid $148.70
Plaintiff Paid
Date: 7/22/09
(Seal)
Other Costs to be added
ISJQA-t? P. [C
R. Long, Prothonotary
By: K . IL
Deputy
REQUESTING PARTY:
Name GREGG L. MORRIS, ESQUIRE
Address: PATENAUDE & FELIX, APC
213 E. MAIN STREET
CARNEGIE, PA 15106
Attorney for: PLAINTIFF
Telephone: 412-429-7675
Supreme Court ID No. 69006