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Home My WebLink About06-7072 T rN "HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION --ACV OF COLORADO, LLC Plaintiff vs. DA'JID R DOUGHERTY Defendant NO: 01. COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAQ:: 412-338- 7130 05284078 C E Pit KEB L7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. Ci?,'i.l Action No DA'I' D R DOUGHERTY De--- :,ndant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. It 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 an 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 cozr-t without further notice for any money claimed in the complaint or fog any other claim or relief requested by the plaintiff. You may Lose non,y or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAV'," A LAWYER OR CANNOT AFFORD ONE, JO TO OR TELEPHONE THE OFFICE SET FOR H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE PO 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 C7 COMPLAINT 1. Plaintiff, CACV OF COLORADO, LLC is a corporation with offices at 370 17TH ST.,SUITE 5000 DENVER , CO 80202 . 2. Defendant is adult individual(s) residing at the address listed betDw: DAVI=D R DOUGHERTY 400 BRICK CHURCH RD FNO L,A, PA 17025 3. Defendant applied for and received a credit card bearing the acc:)unt number 4465610200805600 . 4. Defendant made use of said credit card and has a current balance due of $4489.66 , as of September 21, 2006 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to P l-ii.ntiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.0000 per annum on the unpaid balance from September 21, 2006 . A copy of Plaintiff's STATMETN is attached hereto, marked as Exhibit "i" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and agiinst Defendant , DAVID R DOUGEERTY , INDIVIDUALLY , in the amount. of $4489.66 with continuing interest thereon at the rate of 6.000% per annum from September 21, 2006 plus costs. Jam s C. Warmbrodt,42524 4t 1EI M WEINBERG & REIS CO. L.P.A. 43 S venth Avenue, Suite 2718 P'tt? urgh, PA 15219 412 434-7955 'AX. 412-338-7130 05 84078 C E Pit KEB Thi, law firm is a debt collector ?iE:empting to collect this debt for our client and any information obtained will be used for that purpose. BALANCE AS PAYMENT MINIMUM OF 06713102 DUE D+TE PAYMENT ACCOUNT NUMBER 4465-6102-0080-5600 sa,aaa.2e SEP0a,2002 s1,o23.oD D Indieats enrW of .derra on e.cr PROVIDIAN VISA CARD ...1.11..n11llntlultlele Is 1. I I .. II. I I Ito oil I. I I I. t l l r II PROVIDiAN VISA CARD Please be sure PO BOX 8538 .4 this address appears MANCHESTER NH 03100-OM in the window. Iu.IIIn.IIIIII.J.1.1.1u,1111i6lll.et.t1J16..ILttItLtl page 1 oft DAVID R DOUGHERTY 400 BRICK CHURCH RD ENOLA PA 17025-2202 446561Q2UU8Q56aaala23QOU4899260D00a F-Iyi?? Y---our--accou----nt---Is -i s----sued--by--P--ro--vidi-s-n--Natio-----nal- Bank----,-T--ilton---, --NH -. ----------------------DETACN ---- HERE-0 -- CARD YOUR PAYMENT IS LATE AND YOUR ACCOUNT IS OVER ITS CREDIT UNEi Your atxcunt may be closed due to nonpayment. To avoid further collection efforts, please send the past due amount of $877.00, or call us at 14800.918-9180 today. Paying lust the minimum amount due will not change your overilmit status. Please send the required funds to ensure your account balance to within your approved credit limit. PROVIDIAN VISA CARD TRANSACTIONS st Date Description Trans Date Reference Number punt 07-29CREDIT PROTECTION FEE 07-28 74168512210106210573935 0000 7.95 08-13OVERLINIT FEE 08-13 0000 29.00 08-13LATE PAYMENT CHARSE 08-13 0000 35.00 FOR BILLING ERRORS AND IMPORTANT INFORMATION, SEE REVERSE SIDE. ACCOUNT SUMMARY ACCOUNT NUMBER 4465-6102-0080.3600 Previous Balance $4,728.77 Days in 8110V Cycle 32 - Credits AO Stsbmn rtt Date OSM3102 - payments AD Minimum Parymerd $1,023.00 + Purchases & Other Charges 29AD Payment Due Date 08/)W2 Ca E AO Credit Line $3 77&0 + CHARGE. YANANC On Balances 10054 Available Credit as of Statement Date 1 5.00 Credit protection Fee 7.85 Available Credit br Cash Advances as of Statement Date 5.00 + Late Charge 35.00 Average ANNUAL Daily (Prowlem Due Date 0948) Type of Balance Daily PERCENTAGE Periodic = NEW BALANCE $4,89828 Balance RATE Rate PUrehase :4,75031 2328% .085728% Cash Advance S.00 23A8% 1185728% For 24-hour Automated Account Information, call 1-600-356-0011 or visit us at www.providiantmline.com. L? S ?-T L11O7g AMOUNT ENCLOSED take Cheeks Payable to Providian 000000000 3611 1540 BALANCE AS PAYMENT • MINIMUM I OF OW AIM DUE DATE PAYMENT AMOUNT ENCLOSED ACCOUNT NUMBER ? 4465-6102-0080-5600 sa,aaa.zs sEP za, zaoz $1,170.007 indicate clu nee of sddraa on bock Make Checks Payable to PROVIDIAN VISA CARD Providian 11111111111tt1111111111111 It 11 t1111rtr1111111 Nell 1111111111111 PROVIDIAN VISA CARD Please be sure PO BOX 9530 this address appears MANCHESTER NN 03108-OW in the window. (1t1111u1111nn11r111tIt1tIII Is 11111loll 13111ut11111111111 Page 1 of 1 DAVID R DOUGHERTY 00MM 220 400 BRICK CHURCH RD ENOLA PA 17025-2202 44b56102008056000117000048992600000 DETACH-----HERE A -- - -----a c--coun---t--Is -I s----sued--by--P--ro---vidian---Natio-----nal- Bank----,---Tilton---, -N-H ----------------------- Your PROM YOUR PAYMENT IS LATE AND YOUR ACCOUNT IS OVER ITS CREDIT LINE! Your account may be closed due to nonpayment. To avoid further collection efforts, please sand the past due amount of $1,023.00, or call us at 1-800-910-9180 today. Paying just the minimum amount due will not change your ovedimit status. Please send the required funds to ensure your account balance Is within your approved credit limit. PROVIDIAN VISA CARD TRANSACTIONS Post Date Description Trans Date Reference Number Amon No Activity This Month FOR BILLING ERRORS AND IMPORTANT INFORMATION, SEE REVERSE SIDE. ACCOUNT SUMMARY ACCOUNT NUMBER 4465-6102.0000-5600 Previous Balance $4,89928 Days in Billing Cycle 15 - credits .00 Statemend Date (ISAAV 02 - Payments .00 Mhdmu n payment $1,170.00 + Purchases i Other Charges .00 Payment Due Data 00124412 + Cash AdvarNas .00 Credit U + FINANCE CHARGE na $3,77800 Bal lancon; Available Credit as of Statement Date 5100 + n Ch ia rge 00 Available Credit for Cash Advances as of Statement Date S.00 s NEW BALANCE 540926 Average ANNUAL Daily Type of Balance Daft' PERCENTAGE Periodic Balance RATE Rate Purchase $.00 0.00% ADD= % Cash Advance $.Do O.OO% .000000% For 24-hour Automated Account Information, call 1.800-358-0011 or visit us at www.providianonline.com. n? sun ,ow VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsifications to authorities that she is Dawn Rannells, Authorized Agent of CACV of Colorado, LLC, plaintiff herein, that she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. WWR#D52??Hm?) IJ a too IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. DAVID R DOUGHERTY Defendant No.: 06-7072 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#05284078 Judgment Amount $ 4580.43 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. Civil Action No.: 06-7072 CIVIL TERM DAVID R DOUGHERTY Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, DAVID R DOUGHERTY above named, in the default of an Answer, in the amount of $4580.43 computed as follows: Amount claimed in Complaint $4489.66 Interest from SEPTEMBER 21, 2006 TO JANUARY 22, 2007 at the legal interest rate of 6.00% per annum $90.77 TOTAL $4580.43 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#05284078 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 400 BRICK CHURCH RD ENOLA,PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. Civil Action No.: 06-7072 CIVIL TERM DAVID R DOUGHERTY Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order ?d?gpn ent was entered against you onIr U 1-,2067 (xx) Assumpsit Judgment in the amount of $4580.43plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Protho tary By: P THONOTARY DAVID R DOUGHERTY 400 BRICK CHURCH RD ENOLA,PA 17025 Plaintiff's address is: c/o Weitman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff case # r)(o -707A tvtI -rzrO DAVID R DOUGHERTY Defendant(s) IMPORTANT NOTICE TO: DAVID R DOUGHERTY 400 BRICK CHURCH RD ENOLA,PA 17025 Date of Notige: ? W ( C2 l a00-Z WWR#: 05284078 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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 SOUTH BEDFORD STREET \--- ---,- -_? CARLISLE, PA 17013 (717) 249-3166 -? BY: JAMES BRODT, ESQUIRE PA I #42524 WEL WEINBERG & REIS CO., L.P.A. 27Y8/KOPPERS BLDG, 436 7TH AVE. P7 SBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO, LLC Plaintiff vs. DAVID R DOUGHERTY Defendant Case no:: 06-7072 CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, DAVID R DOUGHERTY is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, DAVID R DOUGHERTY is not in the military service. Further Affiant sayeth naught. [V ij AFFIANT SWORN TO AND SUBSCRIBED in my presence this a 3 day of TAn ar a[Y? l c._.._. MM®NW€ALYMOFPSNNSYLVA ? ,.,1 ? Notarial Seal ? ? NOT Y PUBLI Wayne A Jones, Notary Public City Of Pittsburgh Allegheny County My Commission Expires June 29,201o Member, Pennsylvania Association of Notaries This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center AOL Military Status Report W Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JAN-22-2007 06:58:16 -< Last Name First/Middle Begin Date Active Duty Status Service/Agency DOUGHERTY DAVID R Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. Aht in Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. # 167;# 167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. defenselink.mil/faa/pisiPC09SLDR.htmi See. W://www.defenselink..mil/faa/t)isiPC09SLDR.htmi WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 1/22/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BNYYXQIPCHJ https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 1/22/2007 -Ti __., T C.? J{TI - 1 SHERIFF'S RETURN - REGULAR CASE NO: 2006-07072 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO LLC VS DOUGHERTY DAVID R KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DOUGHERTY DAVID R the DEFENDANT , at 2015:00 HOURS, on the 12th day of December-, 2006 at 400 BRICK CHURCH ROAD ENOLA, PA 17025 DAVID DOUGHERTY by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.08 Affidavit .00 Surcharge 10.00 .00 42.08 lIl'/y 7 Sworn and Subscibed to before me this of day So Answers: 7000_? R. Thomas Kline 12/18/2006 WELTMAN WEINBERG REIS By. A. D. o/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff vs. DAVID R DOUGHERTY Defendant No. 06-7072-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (LEVY ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5284078 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff vs. Civil Action No. 06-7072-CIVIL TERM DAVID R DOUGHERTY Defendant PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against DAVID R DOUGHERTY, Defendant y? 3. Judgment Amount $ 4580.43 - ?!/AO. ?l3 Less payments of $ (400.00) Interest $ 35.29 Costs $ SUBTOTAL: $ 4215.72 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: W William T. Molczan, E uire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#5284078 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO LLC Plaintiff vs. Civil Action No. 06-7072-CIVIL TERM DAVID R DOUGHERTY Defendant WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against: DAVID R DOUGH ERTY_Defendant(s); (1) You are directed to levy upon the property of the defendant(s) and to sell his/her/their interest therein; (2) You are also directed to attach the property of the defendant not levied upon in the possession of N/A, as garnishee, N/A and to notify the garnishee that: a. An attachment has been issued; b. Except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant and from delivering any property of the defendant or otherwise disposing thereof; c. The attachment shall not include any funds in an account of the defendant with a bank or other financial institution i. In which funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law, or ii. That total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant's general exemption provided in 42 Pa.C.S. § 8123. (3) If property of the defendant not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify [him] such other person that he or she has been added as a garnishee and is enjoined as above sated Amount due .......................................... $ 4215.72 Costs to be added .................................. $ Prothonotary Deputy DATED: WWR#5284078 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CACV OF COLORADO LLC Plaintiff No. 06-7072-CIVIL TERM vs. DAVID R DOUGHERTY Defendant WRIT OF EXECUTION NOTICE This paper is a "Writ of Execution". It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken and sold by the Sheriff to satisfy your debts. SUCH PROPERTY IS SAID TO BE EXEMPT. No matter what you may owe, there is a DEBTOR'S EXEMPTION established by law. This means that no matter what happens, the Sheriff must give you from the sale at least $300.00 in cash or property. There are also other exemptions which may be applicable to you. Listed below is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Complete the claim form on the opposite side and demand a prompt hearing. (2) Deliver the form or mail it to the Sheriffs Office at the address noted. You should come to court when and where you are told to appear ready to explain your exemption. IF YOU DO NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR PROPERTY. 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 TELEPHONE NO.: (717) 249-3166 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 exemptions set by law. 2. All wearing apparel used by yourself and all family members. 3. Bibles, school books, sewing machines, uniforms & equipment. 4. Tools of your trade such as carpenter's tools. 5. Most wages & unemployment benefits. 6. Social Security benefits, certain retirement funds and accounts. 7. Certain veteran & armed forces benefits. 8. Certain insurance proceeds. 9. Such other exemptions as may be provided by law. CLAIM FOR EXEMPTION TO THE SHERIFF: I, the above-named defendant, claim exemption of property from levy or attachment: (1) FROM MY PERSONAL PROPERTY IN MY POSSESSION WHICH HAS BEEN LEVIED UPON, (a) I desire that my statutory $300.00 exemption be: (__) (1) set aside in kind (specify property, to be set aside in kind: (__) (2) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption: (specify property and basis of exemption): (2) FROM MY PROPERTY WHICH IS IN THE POSSESSION OF A THIRD PARTY, I CLAIM THE FOLLOWING EXEMPTIONS: (a) my $300.00 statutory exemption: in cash (_) in kind (specify property): (b) Social Security benefits on deposit in the amount of $ (c) Other (specify amount & basis for exemption): I request a prompt court hearing to determine the exemption. Notice of hearing should be given me at the following: ADDRESS: TELEPHONE NUMBER: I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsification to authorities: Date: Defendant: THIS CLAIM TO BE FILED WITH: Office of the Sheriff of Cumberland County One Courthouse Square, Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone Number: (717) 240-6390 Note: Under paragraphs (1) and (2) of the Writ, a description of specific property to be levied upon or attached may be set forth in the Writ or included in a separate direction to the Sheriff. Under paragraph (2) of the writ, if attachment of a named garnishee is desired, his name should be set forth in the space provided. Under paragraph (3) of the writ, the Sheriff may, as under prior practice, add as a garnishee any person not named in this writ who may be found in possession of property of the defendant. See Rule 3111(a). For limitations on the power to attach tangible personal property, see Rule 3108(a) (b). Each court shall, by local rule, designate the officer, organization or person to be named in the notice. N C) °c? gri ?.. ? G,, Vt 5J r- `Q, w H. b z I -co vxo h .? d cn e c 00 ° 00 S^ _? co WELTMAN, WEINBERG & REIS Co., L.P.A. ATTORNEYS AT LAW 2601 Koppers Building 436 Seventh Avenue (412) 434-7955 CLEVELAND . COLUMBUS . CINCINNATI . PITTSBURGH June 7, 2007 RE:®1-t? .,1 I?,YlOC4? vs. COURT 2- I V 1 LTErLly, TO THE SHERIFF OF COUNTY: PLEASE LEVY ON ALL PERSONAL PROPERTY OF THE DEFENDANT(S) AT THE FOLLOWhNO-ADDRESS(ES): ?Z2)rX-.i A Q L c)c? , . . Lc)p ??)ta PfA az PLEASE CONFIRM SERVICE BY SENDING NOTICE TO: WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 (412) 434-7955 u, - WWR# Zu WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7072 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CACV OF COLORADO LLC, Plaintiff (s) From DAVID R. DOUGHERTY, 400 BRICK CHURCH RD., ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PERSONAL PROPERTY OF THE DEFENDANT . (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 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 $4,180.43 L.L. $.50 Interest $35.29 Atty's Comm % Atty Paid $133.58 Plaintiff Paid Due Prothy $2.00 Other Costs Date: JULY 30, 2007 (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE -k A2SI Curtis 4Long, Pro ry By: Deputy Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ 4F Advance Costs: 150.00 81.06 18.00 $ 68.94 10.00 .50 2.00 Refunded to Atty on 09/10/07 10.56 20.00 20.00 81.06 J 91IY16So Answers; . Thomas Kline, 5 eriff C--A By Claudia A. Brewbaker 00 .zti d Z- 91V LOoi o? I?j 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7072 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CACV OF COLORADO LLC, Plaintiff (s) From DAVID R. DOUGHERTY, 400 BRICK CHURCH RD., ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PERSONAL PROPERTY OF THE DEFENDANT . (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 attachment is found in the possession of anyone other than a named gunishee, you are dizeewl to, notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,180.43 L.L. $.50 Interest $35.29 Atty's Comm % Atty Paid $133.58 Plaintiff Paid Due Prothy $2.00 Other Costs Date: JULY 30, 2007 (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE R. Long, By: Deputy Address: WEL'TMAN, WEiaG & CO., L.P.A. 2718 KOPPERS BU1II.DING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 SHAPIRO LAW OFFICE, P.C. Kenneth S. Shapiro, Esq. Attorney I.D. #26850 712 Darby Road P.O. Box 20 Havertown, PA 19083-0210 (610) 668-0707 ilk` LIE: �E ��PRO HO , Til 2014 JUL 22 41110: 10 CUNSERL PENNS AND COUNTYI No. of Pages I Court Of Common Pleas CUMBERLAND County, PA CACV OF COLORADO, LLC Plaintiff v. David R. Dougherty Defendant(s) CIVIL CASE NO. 2006-07072 ENTRY OF APPEARANCE TO THE DIRECTOR OF THE DEPARTMENT OF COURT RECORDS OF CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION): Kindly enter my appearance on behalf of CACV OF COLORADO, LLC, Plaintiff herein. I hereby certify that this change is not intended to, nor will it, delay this proceeding to the best of my knowledge, information and belief. Papers may be served at the address set forth below: Dated: JUL `'G 2014 EW866 Kenneth S. Shapiro, Esq. Attorney ID # 26850 Shapiro Law Office, PC 712 Darby Rd P.O. Box 20 Havertown, PA 19083-0210 Telephone # 610-668-0707 FAX # 610-668-1815 Respectfully submitted, SHAPIRO LAW OFFICE, For the fi