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HomeMy WebLinkAbout02-2202IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMERICHOICE FEDERAL CREDIT UNION, Plaintiff EDWIN S. SHEIBLEY and MARIBETH SHEIBLEY, Defendants CIVIL ACTION - LAW _NOTICE You have been sued in Court. If you wish to defend against the claims set fo/th in th you must take action within twenty, r20x da-'s after'~-: ........... e following pages, ¥ ~ / ff un~ ~omplalntana INoIlce IS S ' a,pp. earance~, personally or by attorney and illin,, i -~;*:-~-.:-L .L .... e~ed, by en.te, nng a written creams set t0rth against vou You ~--~o,~,~ ,~Z :ne/;~:.~'~ .~_'~ me ~°urt your ae~enses or o~jections to the judgment may be entered a~ainst you "~'~.~.?--~-L'~" t.o. ~o .s.o, the c~.ase may proceed withoutyou and a .... .~ ..~. ,.~am t .w. ~mom runner nonce fo.r ~y money claimed in the Complmnt, or document, or for any other clmm or rehefrequested bv the Plm property or other rights important to y~, ~ nuff. You may lose monegr YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICIA Le han demandado a used en la eorte. Si used quiere defenderse de estas demandas expuestas en las paginas siguientes, used tiene viente (20) dias de plazo al partir de la feeha de lademanda la n Used debe presentar una aoarienciae '* ..................... Y otificacion. ~ scrl~ ~ .~. }.,~..u,,a u pot aoogaoo y arcmvar en la torte en forma escrita sus defensas osus objeciones a las demandas en contra de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y puede entrar una orden contra used sin previo aviso o notificaciony por cualquier queja o alivio que es pedido en la peticion de demanda. Used puede perder dinero osus propiedades o otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 800-990-9108 Document #.. 209769.1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMERICHOICE FEDERAL CREDIT UNION, : NO. O ~. ~ ~x Plaintiff : VS. ; ; EDWIN S. SHEIBLEY and : MARIBETH SHEIBLEY, : : CIVIL ACTION - LAW Defendants COMPLAINT AND NOW, comes Plaintiff, Peoples State Bank, by and through its attorneys, Metzger, Wickersham, Knauss & Erb, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, AmeriChoice Federal Credit Union, is a financial institution qualified to conduct business in the Commonwealth of Pennsylvania with offices and/or a place of business situate at 20 Sporting Green Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendants, Edwin S. Sheibley and Maribeth Sheibley, are adult individuals with a last known address of 1107 Floribnnda Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Defendants, Edwin S. Sheibley and Maribeth Sheibley, are, and at all relevant times material hereto was, the primary loan applicants. 4. On or about October 26, 2000, Defendants applied to Plaintiff for a loan for the purpose of purchasing a motor vehicle. A true and correct copy of the loan applications are attached hereto, incorporated herein and marked as Exhibit "A". Document #: 232773.1 5. The loan application submitted by Defendant was approved by Plaintiff and Defendant signed the Motor Vehicle Installment Sale Contract (hereinafter referred to as "Contract"). A true and correct copy of the loan applications are attached hereto, incorporated herein and marked as Exhibit "A". 6. The Contract marked as Exhibit "B" contained the terms and conditions of the extension of credit agreed to by the Defendant. 7. Defendant accepted the monies borrowed from Plaintiff pursuant to the terms and conditions of the Contract. 8. As a result of Defendants' default and failure to cure such default in payment, Plaintiff repossessed and sold the 1988 Volvo VIN: YV1FX8848J2287969, whereby a resulting deficiency balance existed. 9. Plaintiff has maintained a statement of account, keeping an accurate and running amount of debits and credits made on Defendants' account. 10. Plaintiff has submitted to Defendants a copy of the statement of account accurately showing all debits and credits for transactions with Plaintiff. 11. Defendants have not objected to any of the monthly statements of account submitted by Plaintiff to Defendants. 12. Despite Plaintiff's reasonable and repeated demands for payment, Defendants have failed, refused and continues to refuse to pay all sums due and owing on Defendants' loan account balance, all to the damage of Plaintiff. 13. As of March 20, 2002, the balance due, owing and unpaid on Defendants' loan account with Plaintiff is the sum of Eleven Thousand Six Hundred Fifty-Five and 10/100 Dollars Document #: 232773.1 ($11,655. lO). 14. Pursuant to the terms and conditions of the extension of credit contained in the Contract, Plaintiff is entitled to receive and Defendants agreed to pay an annual interest charge at a rate of 12.99% on the principal loan balance. 15. Pursuant to the terms and conditions of the extension of credit as set forth in Exhibit "A", Defendants agreed to pay reasonable attorney's fees and ail court and collection costs. 16. Plaintiff has retained the services of the law firm ofMetzger, Wickersham, Knauss & Erb, P.C. in the collection of the amounts due and owing by Defendant. 17. As of the filing of this Complaim, Plaintiff has incurred reasonable attorney's fees from the law office ofMetzger, Wickersham, Knauss & Erb, P.C. in the collection of the amounts due from Defendant incident to the within action, and Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 18. The amount of attorney's fees incurred in this matter is the sum of Two Thousand Three Hundred Thirty-One and 02/100 Dollars ($2,331.02). 19. by Plaintiff. 20. arbitration. Any and all conditions precedent to the bringing of this action have been performed The amount in controversy is within the jurisdictionai amount requiring compulsory WHEREFORE, Plaintiff, AmeriChoice Federal Credit Union, respectfully requests this Honorable Court to enter judgment in favor of Plaintiff and against Defendants, Edwin S. Sheibley and Maribeth Sheibley, in the amount of Eleven Thousand Six Hundred Fifty-Five and 10/100 Dollars ($11,655.10), plus interest at an annual rate of 12.99%, reasonable attorney's fees in the Document #: 209769.1 amount of Two Thousand Three Hundred Thirty-One and 02/100 Dollars ($2,331.02), the costs of this action, and such other relief as the Court deems just and proper. Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: April 24, 2002 By: Steven C. Co~~ (717) 238-8187 I.D. # 74669 Attorney for Plaintiff Document #.- 209769.1 o4/o~/~oo~ o7:.~4 FAX 7172340474 I, Stev~n Bon~, hereby ~ fh~ ~ho followt~ is correct: Thc ~*ts set forth in the'foregoing Complaizit ere b~cl :~ * · ~pon :~on which I have furnished to counsel, as ' '. ' ' ~J~ ~ up(m ~ma~on w~tch ~m b(~u SaT~d by ~ i~o~ ~i~S on my ~l~lf i~ ~s mawr: The ~e' of ~.Com~,.~.. ~ ~ ~.Of ~om~ ~d ,,~, ,~ o~ I~ve~,~,~m 1~ . ' ' ~' "'..Y:~:"""~'~.~,'.'"':'~"" ' -- P ., ~ m.~.~t ~Kit ...... · . ...'.' ~:..~.....~ .... · ....~. ... Date: Exhibit A IERI-~.HOICE FEDERAL CREDIT U, JN ~porang Green Drive ~anicsburg, PA 17055 1107 FLORT~J~DA LN M~u,~N~C~BtT~G, PA 17055-5302 NOTE AND DISCLOSURE STATEMENT 10/26/00 23955-063 1012102 N I~N lOAN CoN'n~,CT CC080967 2/01/06 Co-aDD: ~I~'~ S~IB~ i1_ . ~7-1~-3 s ~ment "~u" and 'y~r" m~n e~h ~rson w~ s~ns ~is ~eme~. ~ "ot~unien" ~a~ ~e credit union w~e ~ appears abov, ~n~e ~ w~m ~e cr~A un~n ~sfers i~ ~h~ u~r ~is agre~em. ~e ~s on ~e followi~ p~;; am ~ of ~is agr~m. Boxes ~d ~ow ep~y m ~is ~m~ent. .................. ~4:~ ~~, ~~~t .na~ T~I ~ ~yme~ I~Ym~? If you pay off :~t ~ ~ ~d~ ~ a ~alv am. ' ~'~r ~;~g~ ~ O~ ~e m~um of ~ I~e I~ ~u will nave learly you will ~t ~ve to pay wMl ~t ~u. IPm~ded m ~u or on your · 2.990 % t 5,2[0.8( I $ 13,553.85 /S ~8,?6~.69 I emea~anegtlmam N~r ~ ~W Aa ~ ~ Fa~ W~ ~m Am ~ IE,~[~ I~; Y~ may ~b[i;n pm~ I~bM ~ 62 S 300.00 [2/01/00 ~ '~:~ Iinsuta~e from ~ emd~ un~n ~u will pay S 164.69 2/0[/06 I ~ Colla~ral ~cu~ other loans wi~ the ur~ union will slso sKu~ ~ Io~. You are givi~ a ~u~ inte~ in your shares ~ ~ ~d~ ~i~; and~ ~ t~ go~a/pm~ being purc~d; ~ (Describe) 88 ~. ChMge: [E any pot:ion o~_yo~r paym~_t is m~_re ch~n 15 cra. Ts lace, y~u w[l~zncur a ~15.00 late cringe. ~ Defmslt: The Annual Pementage Rate does no~ take into account your required deposit, if lFilim3 Fee~ [, MIA INon-.Filing Insumnoe ~ eontraot documents for any additional infatuation about nonpayment, default, and any required repayment in full before the I albTATION OF THE AMOUNT FINANCED ZATION OF AMOUNT C~VEN AMOUNT PAID ON ~JD FINANCE J~T/NNANCEDOF $ 13,553.85 TO YOU OIRECTLY $ 10,568.31 YOUR ACCOUNT $ NIA Ct4A~E S N/A JNT PAID 1'0 OTHERS $ 886.54 FOR CREOIT INSURANCE l) $.00 To COMM OF PA 3UR aI~LF $ NIA To' $ NIA To $ 2,094..00 To GARY ALFERY $ N/A To ....... .~e, TURE: If you agree to and be bound by the terms of this Note and Security Agreement sign below. If you are a gorrower but an owner of zhe collateral for this loan. sign below and check zhe box for "Owner of Collateral'. 8y .g so you agree only to the terms of ~he Security Agreement. mON: IT IS IMPORTANT THAT YOU THOROUGHLY READ THIS CONTRACT BEFORE YOU SIGN IT. Exhibit B -~Cho'~¢e Fed~ra[ Credit Uhio~ " EDWIN S. ST~R-I]~LEY 23-~ -063 Oate 10/26/00 ND SECURI~ AGREEME~ ,, m ~y: Y~. promi~ to pay ~ 13. S53,85 to ~ ;rede; union pl~ i~etest on ~e unpaid ~l~ce at 12.~9o % per year until what y~ owe repaid. ,trion Costs: JRITY oFFERED: MODEL YEAR I.D. NUMBER TYPE VALUE VOLVO I VOLVO 88 YVIFX8848J2287SES A $ .00 $ t ~E$CR~E) ~J~OG$ OF SHARES $ ACCOUNT NOiS{. Note is governed by the laws of PA. 'MENTS - You promise to make payments of the amount and · ~e time shown in the Truth in Lending Disclosure on page 1 what you owe has been repaid. You may make larger · ne~s without penalty. If you do prepay part of wh~ you ., subsequent payments will remain due as sch~d~ed. If you not make payments as anheduled or if you elect credit rence, your last payment may be larger than the amount of other payments. You promise to make payments at the place ~en by the credit union. · i~ BY MAIL - If this loan is being made by mail, interest on Iosn begins when the loan procesde are mailed. If thle loan ~ances an eadier loan. said loan will be cancelled and tanced as of the date on page 1. .1JRITY U~]:~EST - Any mnperty shown in the 'Security ~red" seotion will be security for this loan. In addition, you ~e this loan le also secured by all the shares and deposits in all r Individual and joint accounts with the credit union now and he future. Shares and deposits in an Individual Retirement ount and any other account that Would lose speoiai tax ~rnent under state or federal law if given as security am not ~eet ~o the security interest you give in your shares and gaits. All preperty, other than dwellings, that you have given ~e;ure other loans with the credit union will also secure this :AULT - You will be in default if you do not make a payment he emm~nt required when k is due. You will be in default if break any promise you made in connection with this loan. ~ will be in default if you die, fils for bankruptoy or become ~vent, that ia, unable to pay your obligations when they oma due. You will be in default if you make any false or leading statements in any credit application or ulxlate of credit R TENNESSEE CREDIT UNI~N~ ONLY - E WHEN AUTOMOBILE IS PURCHASED ~TICE: If you do not purchase the insurance required on the :omobile and the oradit union purchases the insurance, the urence purchased by the credit union will cover only the credil oh'S interest in the property. The insurarme will not be liability ureas. You have read the above statement and acknowledge · the credit union has explained it to you. OA~ DATE information. You will be in ~l~fauit if anyone who has signed a security agreement in conneotion with this loan is in default. You will also be in default if something happens which the credit union believes may substantially reduce your ability to repay what you owe. When you are in default, the credit union can demand immediate paymen~ of the unpaid balance of this loan wkhout giving you advance notice. If the credit union demands immediate payment of the unpaid balance, you will continue to pay interest at the' same interest rate until what you owe has been repaid. If the credit union has demanded immediate paymen~ of the unpaid balance, the credit union can apply the shares and deposits that you have given as soqurity under this agreement towards what you owe. The credit onion can also exercise any other rights the law gives the credit union when you are in default. EACH PERSON RESPONSIBLE - Each person who signs this agreement will be individually and jointly responsible for paying the entire amount owed, That means the credit union can enforce its righ~ under this agreement against any one of you individually or against all of you together. LATE CHARGE - If you ere late in making a payment, you agree to pay the late charge shown in the Truth in Lending Disclosure on page 1. If no late charge is shown, you will not be nharged one. NO WAIVER - The credit union can delay enforcing any of its rights any number of times without losing its rights. NOTICES - Not]oas will be mailed to you at the mo~ recent address you have given the credit union in writing. Notice to any one of you will be notice to all. FOR NORTI~I DAKOTA CREDIT'UNION8 ONLY - APPLIES ONLY WHEN A MOTOR VEHICLE IS PURCHASED NOTICE: THE MOTOR VEHICLE IN THIS TRANSACTION MAY BE SUBJECT TO REPOSSESSION. IF tT IS REPOSSESSED AND SOLD TO SOMEONE ELSE, AND ALL AMOUNTS DUE TO THE SECURED PARTY ARE NOT RECEIVED IN THAT SALE, YOU MAY HAVE TO PAY THE DIFFERENCE. FOR CREDIT UNION USE ONLY: Credit Union Approval X rlCho'~,.e Federal Cre~1~ Unf~ ~--'~./A ~ AGR~MENT n~ment ail refem~es to "cr~E union" mean the credit whose name appeam ~ this n~ ~d a~yo~ union assigns ~ loan. All references to '~ I~n" mean ~e ~scHb~ in t~ Tr~ in Le~ing Diacl~ure. All m~re~es to mean ~ch ~mon who signs ~is ~reement. S~URI~ FOR ~E LOAN - By signing' this ~cur~y ~ent in the sign~um area or by s~ning ~e s~ment ~ m this agreement on ~e back of ~e G~ck you receive for I~n, you give ~ cmdA union what is ~wn as a se=uriW ~t in the p~ny ~scribed in the 'Secur~ O~red" ~i~. sscu~ in, rest you give i~l~aa all ac~ss~. Ac~ssions · ~gs which are a~=~d te or i~talled in t~ ~o~ ~w or ~re. T~ secu~ interest also incl~s a~ m~a~men~ ~ prope~ which y~ b~ w~in 10 ~ys of ~ loan or a~ ;~ns, renewals or refinanci~ of ~e I~n. k also includes any .ay you m~e ~om s~li~ t~ pro~ or ~m i~ura~e you ~ ~e pm~y. If the val~ ~ ~e pmpe~ ~lin~, you nlee m give the c~A uni~ more pro~ as ~cur~ · asked 6o. THE S~URI~ INT~ST CO~ - T~ ~u~ ~s ~ loan ~sc~b~ ~ ~e T~ in ~mg Dbc~s~e and ~tsne~, renewals ~ refineries ~ t~t ~. ~s ~y m~r I~ y~ have wkh ~e ~it ~on now or in ~ ~d a~ ~r amou~ you owe ~ c~it union for any new or ~ ~e f~um. If t~ pro~ ~scH~ion is mar~d ~e s~r ('), or the ~y is h~ehold goods as def~ by Cr~k ~acti~ Rule, me ~ will secure ~ this loan and ~r amounts y~ owe. ~HIP OF THE PRQP~ - Y~ promise that you own ~e '~, m if ~ I~n is to bw ~e Dro~, you promi~ you will ~ ~ for that p~. You prorate ~t no one el~ ~s any ~ in or ~aim ~a~st the pro~ ~ you h~e net already ~ ~¢ ~ion a~ You Fom~ not ~ NIl or lease t~ ~ ~ to ~e it as ~ou~y for a loan wl~ an~r ~itor ~ ~ with ~ cr~ union ~ r~. Y~ promi~ you w~l ~ ~ int~st ~ li~ to a~a~ to ~ pr~ ~t~r by ~i~s or by o~refl~ ~ law. ~G T~ SECU~ ~ - If your ~ats f~ ~ ~ope~, you pr~i~ to have the c~it ~ion's ~ i~ s~wn on ~e t~e. ~ c~ ~ion ~y ~ve to m fr~ t~ ~ai~ of ~. If aak~ to do ~, y~ pmmi~ f~J~ ~mmem. You al~ p~i~ ~ do wh~v~ eisa ~ ~OPE~ - Until t~ I~n has ~n ~d ~, you ~ise ~a~;. (1) ~se ~ ~o~ carnally a~ k~p E In 9~ m~ir. ~n wren ~issi~ ~m the o~it ~ion ~om ~ee to t~ ~o~. (3) Inf~ t~ ~k ~ion In writing ~ngi~ yo~ ~mss m ~e ~m~ w~m ~e ~o~ is ~ ~ c~it u~on if t~ ~ b d~ag~, ~olen ~. (6) N~ ocs t~ pro~ for a~ unlawful pu~ose. ~ ~U~NCE, T~ AND ~ - Y~ ~mi~ to pay · ~ a~ ~s (like ~i~r~Jon fe~) d~ on ~ ~ ~ prope~ ine~ ~a~ ~ a~ dam~e. The am~nt =~era~ of the pr~ i~u~ must be ec~ble to the ~n. You m~ pr~e ~ ~ ~a~e ~h a y~ alma~ have, or ~ough a ~licy y~ ~t ~ ~y for. You promise to make the insu?ance policy payable to the credit union and to deliver the policy or proof of cbverege to the credit union if asked to do so. '" If you cancel your insurance and get a refund, the credit union has a right to the refund. If the property is lost or damaged, the credit union can use the insurance settlement to repair the prOperty or apply it towards wha~ you owe. YOU authorize the credit union to indorse any draft or check which may be payable to you in order · for ~he credit union to collect any refund or benefits due under your insurance policy. If you do not pay the taxes or fees on the property when due or keep it insured, the credit union may pay these obligations, but is not required to do so. Any money the credit union spends for taxes, fees or insurance will be added to your loan balance and you will pay interest on those amounts at the same rata you agreed to pay on the loan. If the credit union adds amounts for taxes, fees, or insurance to your loan balance, your payments may be inoreassd by the amount necessary for your loan to be paid off in the same number of months originally scheduled. DEFAULT - You will be in default if you break any promise you make under this agreement. You will also be in default if you are in default under the loan. If you are pledging property, but have signed only aa an 'Owner of Collateral (o*J~r than a Borrower)", you will be in default if anyone is in default who has signed the LOANMNER Note. WHAT HAPPENS IF YOU ARE IN DEFAULT - When you are in default, the credit union can, without advance notice to you, require immediate payment of what you owe on the loan and take possession of the property. You agree the credit union has the right to take possession of the property withob~t going to court and without giving you advance notice, If you are asked to do so by the credit union, you promise to deliver the property at a time and pleos the otedit union chooses. The credit union will not be responsible for any of your other property, hex covered by this agreement, that y~J leave inside the propetW, The credit union will tw to return that property to you or make it available for you to claim. After the credit union has possession of the prOperty, it can sell it and apply the money received to any amounts you owe the credit union. The credi~ union will give you notice of any public sale or the date after which a private sale will be held. The expenses of the credit union for taking possession of and ~elllng the prol~rty will be deducted from the morley received from the sale. Those costs may include the cost of storing the property, preq)aring it for sale and eCmmey'a fees to the extent permitted under stal~ law or swarded under Seation 506(b) of the Bankruptcy Code. The rest of the sale money will be applied to what you owe on the loan. If you have agreed to pay the loan, you will also have to pay any amount that remains unpaid after the sale money has been applied to whet you owe on the loan and under this agreement, You agree to pay Interest on that amount at the same rate as the loan until that amount has been paid. DELAY IN ENFORCJNG RIGHTS AND CHANGES IN THE AGREEMENT - The credit union can delay enforcing any of i~s hgh~...u. nder this agreem .e.nt. any number of times without losing · aD,sty to exercise ~ts rights later. The =redi~ union ~ enforce this agreemerg against your heirs or leagal representatives. If the credit union changes the terms of th loan, you agree that this agreement will oontlnue to protect the credit union. CONTINUED EFFECTIVENESS .. If the law makes any term(s) of this plan unenforceable, the other terms will remain in effect. THE PROPERTY DESCRIPTION IN THE 'SECURITY OFFERED' SECTION IS PART OF THIS AGREEMENT, NOTIt~.' SIGN '1~115 AGRE~,~IEI~ri' ON PAGE 1. C~=e i .-,CATE E OF try oF ~fl~. ely puMio ©ertifie$ that the above and foregoing is a m JO copy f;f 1;he original teourity agreement, e~_e,~_Jl~d, and delivem~t by the rem Eno to the secured patty ~4reln. SECURED PARTY $~GNATURE {If Required) NOTARY PUBUC TOTRL P. 05 sHERIFF'S RETURN - REGULAR c~E NO: 2002-02202 P COMMONWEALTH OF pENNSYLVANIA: coUNTY OF cUMBERLAND AMERICHOICE FEDERAL CREDIT VS S__HEIB___LEY EDWIN S ET AL sheriff or Deputy Sheriff of unty,Pennsylvania, who being duly sworn according to law, Cumberland waS served upon sayS, the within COMPLAINT & NOTICE ___----- the SHEIBLEY EDWIN S 2002 DEFENDANT ~, at 1932:0-90 HOURS, on the 8___t~ day of M~ ~, ~- at 1107 FLORIBUNDA LAIqE _ ~ by handing to MECHAIqICSBURG, PA 17055 EDWIN SHEIBLEY__ together with a true and attested copy of cOMPLAINT & NOTI___CE__ _ _ and at the same time directing ~i~ attention to the contents thereof. Sheriff's CostS: 18.00 Docketing 7.59 Service .00 Affidavit 10.00 Surcharge .00 ---35.--59 - sworn and Subscribed to before me this d__~,c~_ day of ~ J_~3z3 .L~ __ A.D. -------~thonot ~ry So Answers: SHERIFF,s RETURN - REGULAR ~'!SE NO: 2002-02202 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERIcHOICE FEDERAL CREDIT VS SHEIBLEY EDWIN S ET AL BRIAi~ BARRICK _, Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly SWorn according to law, Says, the within COMPLAINT & NOTICE was served upon SHEIBLEY M-ARIBETH the DEFENDANT , at ~932~..00 HOURS, on the _St~ day of Ma~. , 2002 at 1107 FLORIBUNDA I_~kNE -- -- - MECHANI_CSBURG~PA 17055 MARIBETH SHEIBLEY by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing H__er attention to the contents thereof. Sheriff,s Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 __ .__000 16. 00 Sworn and Subscribed to before me this __33z~x_ day of So AnSwers: R. Thomas Kline 05/09/2002 METZGER WICKERS~ Deputy She~