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Home My WebLink About02-2399WAYPOINT BANK, successor to Harris Savings Bank IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW v. NO. 02'" 0"3 ef~ JALAL M. SHAH and SAQIB J. SHAH Defendants NOTICE 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 / (800) 990-9108 Date: May 15, 2002 KEEFER WOOD ALLEN & RAHAL, LLP Eugene ,~r_.//P e p i n's k~fr ,/ Attomey'l.D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff WAYPOINT BANK, successor to Harris Savings Bank IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW v. NO. 02-- 93 ~ JALAL M. SHAH and SAQIB J. SHAH Defendants NOTICE 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 / (800) 990-9108 Date: May 15, 2002 KEEFER WOOD ALLEN & RAHAL, LLP Attorney'1. D. #23702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff WAYPOINT BANK, successor to Harris Savings Bank Plaintiff JALAL M. SHAH and SAQIB J. SHAH Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de ia demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFIClENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFIClNA CUYA DIRECClON SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 / (800) 990-9108 Date: May 15, 2002 KEEFER WOOD ALLEN & RAHAL, LLP By: fiu~on~insk¥, Jr. Attorney I.D. #23702 210 Walnut Street, P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff WAYPOINT BANK, successor to Harris Savings Bank IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW v. NO. 0~- JALAL M. SHAH and SAQIB J. SHAH COMPLAINT Defendants 1. Plaintiff is Waypoint Bank, successor to Harris Savings Bank, a federal bank, with its principal office at 235 North Second Street, P.O. Box 1711, Harrisburg, Pennsylvania 17105. 2. Defendants Jalal M. Shah and Saqib J. Shah, are adult individuals living and residing at 712 Erford Road, Apartment El, Camp Hill, Pennsylvania 17011. 3. Defendants, as buyers, entered into a Pennsylvania Motor Vehicle Installment Sale Contract with Kuhns Harnish Ford, Inc. A true and correct copy of the said Pennsylvania Motor Vehicle Installment Sale Contract is attached hereto, made a part hereof and marked Exhibit A. 4. The Contract was subsequently assigned to Plaintiff. 5. Defendants defaulted in their obligations under the Contract, and the Vehicle was repossessed. 6. Subsequently, Plaintiff sold the Vehicle, leaving a deficiency balance owing in the amount of $8,411.57. 7. Despite Plaintiff's repeated demands, Defendants have failed and refused and continue to fail and refuse to pay the current balance owed to Plaintiff under the Contract. WHEREFORE, Plaintiff demands judgment against Defendants in the sum of $8,411.57, together with interest, attorneys' fees and costs of suit. Date: May 15, 2002 KEEFER WOOD ALLEN & RAHAL. LLP. By: Eugen~e E. P~y, Jr. Attorney I.D. No. 23,702 210 Walnut Street P.O. Box 11963 Harrisburg, PA 17108-1963 (717) 255-8051 Attorneys for Plaintiff -2- hereby veriflee and state.a ~a~: Harris Savings Bank. Plainliff herein; 3. of (her)hb knowledge, lnformatJofl and belief; (S)He Is authorized to make ~15 Verification on ila behalf;, The fac~ sat forth In t~e foregoing Complaint am b'ue and con'e;t to t~e best 4. (S)He Is aware that false s~alernents herein am made subject to the Penalties of 18 Pa. C.S. § 4904, relating to u.swom raisin, arian t~ authorities. Dated: MAY 14,2002 · F,e ~3-SLC J6/Bg) SIMPLE INTER~'~T ..... PENNS?LVANIA Mo~rORVEHICLE INSTALLMENT SALE CONTRACT, gated DEC 03 1998 -- ~l'"ff'-- I f ANNUAL FINANCE Amount Financed Total of Payments Total Sale Price PERCENTAGE RATE CHARGE The amount of credit provided The amount you will have paid after you The total cost of your purchase on The cost of your credit as The dollar amount the to you or on your bebelf, have made all scheduled payments, credit, including your downpayment a yearly rate. credit will cost you. of $ 3600.2 9.90 % $ 4931.01 $ 17799.99 $ 22731.00 $ 26331.21 Your Payment Schedule will be: Security: You are giving a security interest in the motor vehicle being No. of Payments ! Amount of Payments When Payments Are Due purchased. 60 $ 378,85 Monthly. beginning 17 JAN 99 ! $ N/A Prepayment:If you pay off early, you will not have to pay a penalty. Filing Fees: $ ~,5. O0 Late Charge: If a payment is late, you will be charged 2% of the portion of the payment which is late for each month, or par[ of a month greater than ]0 days, that it remains unpaid. See below and any ether Contract documents for any additioual information about nonpayment, default, any required repayment in full before the scheduled date and prepayment refunds and penalties, e means estimate th this contract KUHNS HARNISH FORD INC weare 6320 CARLISLE PIKE liECHANICSBURG, PA 17056 the SELLER, Name Address JALAL H SHAH 712 ERFORD RD APT Et CAHP HILL PA 1701I Zip Cede You are theBUYER(S}. SAQIB J SHAH 712 ERFORD RD APT EI £AiiP HILL PA 170]] Name(s) Address(es) Zip Code(s) If there is more than one Buyer, each promises, separately and together, to pay ail sums due us and to periorm all agreements in this Contract. TRADE-IN: Yoe have traded in 97 TOYOTA COROLLA the following vehicle: Year and Make Description If a balance is still owing on the vehicle you have traded in, the Seller will pay off this amount on your behalf. You warrant and represent to us that any trade-in is free from lien, claim, encumbrance or security interest, except as shown in the Itemization of Amount Financed as the "Lien Payoff." PROPERTY INSURANCE: You may choose the person through whom insurance is obtained against loss or damage to the Vehicle and against liability arising out of use or ownership of the Vehicle. In this Contract, you are promising to insure the Vehicle and keep it insured. CREDIT INSURANCE IS NOT REQUIRED: Credit Life Insurance and Credit Disability Insurance are not required to obtain credit, and will not be provided unless you sign below and agree to pay the additional cost(s). Please read the NOTICE OF PROPOSED CREDIT INSURANCE on the reverse side. Your insurance certificate or policy will tell you the MAXIMUM amount of insurance available. All insurance purchased will be for the term of the credit. By signing, you select Single Credit Life Insurance, What is your By signing, you select Single Credit Acciden & What is your which costs $ N/A age? Years Health Insurance, which costs $ N/A age? Years ~fe~ Signature of Buyer to be insured for Single Credit Accident & Health Insurance IF YOU DO NOT MEET YOUR CONTRACT OBLIGATIONS, YOU MAY LOSE THE MOTOR VEHICLE AND PROPERTY THAT YOU BOUGHT WITH THIS CONTRACT, AND/OR MONEY ON DEPOSIT WITH THE ASSIGNEE. This Contract is between Seller and Buyer. All dbctesures have been made by Seller. Seller intends to assign this Contract to the Assignee. Itemization of Amount Financed Cash Price $ 18900.00 Cash Downpayment $ 2600,00 Tradeqn Value of Trade-In $ 10000.00 LienPayoffto:YORK RANK ~, T~ $ 8899,79 Unpaid Cash Price Balance $ ]6574.79 .. To Creditlnsurance Company ~ $ N/A - To Public Officials fen : E License, Tags and Registration ~' $ 63.50 REGULAR SHERIFF'S RETURN - CASE NO: 2002-02399 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WAYPOINT BANK VS SHAH JALAL ET AL BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHAH JALAL M the DEFENDANT , at 1857:00 HOURS, on the 17th day of May at 712 ERFORD ROAD APT E1 2002 CAMP HILL, PA 17011 JALAL SHAH a true and attested copy of COMPLAINT by handing to & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 10 35 00 10 00 00 38 35 Sworn and Subscribed to before me this 5~ day of CI~ ~1~2~ A.D. I Prbthonotar~ ' So Answers: R. Thomas Kline 05/20/2002 KEEFER WOOD ALLEN RAHAL Dep~cy ShEriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-02399 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WAYPOINT BANK VS SHAH JALAL ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHAH SAQIB J the DEFENDANT , at 1857:00 HOURS, on the 17th day of May at 712 ERFORD ROAD APT E1 2002 CAMP HILL, PA 17011 by handing to JALAL SHAH a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this j~ day of ~ ~o~b A.D. /Pz~ot honor ary So Answers: R. Thomas Kline 05/20/2002 KEEFER WOOD ALLEN RAHAL ~Deputy}~he ri f f WAYPOINT BANK, successor to Harris Savings Bank Plaintiff JALAL M. SHAH and SAQIB J. SHAH Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2399 NOTICE To: JALAL M. SHAH and SAQIB J. SHAH You are hereby notified that on June 17, 2002, the following Judgment has been entered against you in the above-captioned case. By default in the sum of $8,411.57, with interest and costs of suit. DATE: June 17, 2002 Prothonotar~ f/3~, I hereby certify that the name and address of the person(s) to receive this notice is: Jalal M. Shah 712 Erford Road, Apt. E1 Camp Hill, PA 17011 Saqib J. Shah 712 Erford Road, Apt. E1 Camp Hill, PA 17011 Attorney for Plaintiff WAYPOINT BANK, successor to Harris Savings Bank Plaintiff V. : JALAL M. SHAH and SAQIB J. SHAH Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2399 A JALAL M. SHAH and SAQIB J. SHAH Defendido/a Defendidos/as Por este medio se le esta notificando que el 17 de June del 2002, el/la siguiente (Orden), (Decreto), (Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. By default in the sum of $8,411.57, with interest and costs of suit. FECHA: June 17, 2002 Protonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: Jalal M. Shah 712 Erford Road, Apt. E1 Camp Hill, PA 17011 Saqib J. Shah 712 Erford Road, Apt. E1 Camp Hill, PA 17011 Abogado del' Demandante WAYPOINT BANK, successor to Harris Savings Bank Plaintiff JALAL M. SHAH and SAQIB J. SHAH Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2399 PRAECIPE TO THE PROTHONOTARY: Please enter judgment in favor of Plaintiff and against Defendants by default in the sum of $8,411.57, with interest and costs of suit, for Defendants' failure to answer or otherwise plead to Plaintiffs Complaint. I hereby certify that written notice was given Defendants in accordance with Pa. R.C.P. 237.1 (copy attached). Dated: June 17, 2002 KEEFER WOOD ALLEN & RAHAL, LLP Eugene E. Pepinsky, Jr. Attorney I.D. #23702 210 Walnut Street P. O. Box 11963 Harrisburg, PA 17108-1963 717-255-8051 Attorneys for Plaintiff