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Home My WebLink About02-2915LAVIN, COLEMAN, O'NEIL, RICCI, FINARELLI & GRAY By: Heather Lea King, Esquire Identification No. 86356 By: Stephen J. Amoriello, III, Esquire Identification No. 83574 Penn Mutual Tower, 10th Floor 510 Walnut Street Philadelphia, PA 19106 Attorneys for Plaintiff GENERAL MOTORS ACCEPTANCE CORPORATION 5700 Crooks Road Suite 304 Troy, MI 48098 Plaintiff, VS. NOEL E. GRIFFIE 801 Sandbank Road Mount Holly Springs, PA 17065 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO: 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 obi ections 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. SHERIFF'S RETURN - CASE NO: 2002-02915 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GENERAL MOTORS ACCEPTANCE CORP VS GRIFFIE NOEL E REGULAR RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GRIFFIE NOEL Ethe DEFENDANT , at 0915:00 HOURS, at 801 SANDBANK ROAD MOUNT HOLLY SPRINGS, PA 17065 on the 19th day of June , 2002 by handing to NOEL E GRIFFIE 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 4.83 Affidavit .00 Surcharge 10.00 .00 32.83 Sworn and Subscribed to before me this 2~ day of ~, ~z~_ JLgo~ A.D. ~ ~rothonotary' ' So Answers: R. Thomas Kline 06/20/2002 LAVIN COLEMAN ONEIL Deputy Sheriff YOU SHOULD TAKE THIS PAPER TO A 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 TELEPHONE: 1-800-990-9108 or (717) 249-3166 -2- GMAC SMAITI~u~® A~#EEMENT -- MoIIlhly Paymellt ~ Cul~ber-land J P/~3/IB1 ,fom:~vedby 38 p~memsof I notp~rchaseth~.:*ehk~e) ~: O.~E~] paidby~heeflddthe~se.) N/~ $ N/~ Total ............... $. 11~6.~)'~ a confined single limit of $300,000 for b~ddY inJU property _ use ihe vehl~ ille~. Impmeedy, for t~e, or as a Pa:ac co~.~ance. includes. (a) glass that is damaged o~ Ihat you ti~, (b) a damaged or .c~o~...b~:lY, trim! ~mme ~me~t~aer susoer~on engir~, powertmin o other mechanical part; lc) aamageo Exhibit B TITLV L 001. 0'"'~009-63G0~4 /00039 FILE O008G PSHIP 1GNDT13WO12106654 IIIIIIIIIIIIlllllllllllllllllllKIIIIIlllllll Exhibit C GENERAL MOTORS ACCEPTANCE CORPORATION 555 Business Center Drive Horsham PA 19044-3601 1-800-200-4622 BRANCHI~ TI~OUGHOUT ~ OFFICES June ~, 2001 Noel E Gri£fie 801 Sandbank Rd Lot 12 Mount Holly Springs, PA 17065 Re: 020-6183-90966 Dear Noel E Griffie: Under the terms of your lease agreement, we have taken your leased vehicle. It is to be held at Forbes Chevrolet, 3400 Hartzdale Dr, Camp Hill, PA. It must be held at least until 9:00 a.m. June 22, 2001. It will be sold at a private sale at any time after that. If the vehicle is sold, GM_AC will apply the proceeds of sale as provided in your lease agreement. If the net proceeds are less than the total amount you owe, you still owe the balance. If you have insurance or a service contract through GM, GM_AC, MIC or CIM as part of your contract, we will cancel it. Make sure any other coverage you no longer want is canceled. Call the insurance company or the dealer to do this. You have a right to credit for any refunds. If you have any questions, please call the phone number above. J. J. Lumpkin Customer Relations Analyst WE ARE ATTEMPTING TO COLLECT THE AMOUNT OUR RECORDS SAY YOU OWE US NOW. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. Exhibit D GENERAL MOTORS ACCEPTANCE CORPORATION Mailing Addr~: PO BOX 7041, Troy, MI 480077041 Tdephon~ 800-5514377 TE~ WOR1.D July 30, 2001 NOEL E GRIFFIE 801 SANDBANK RD LOT 12 MOUNT HOLLY SPRINGS, PA 17065 Account Number 020-6183-90066 -Dear NOEL E GRIFFIE: We have determined the amount you owe upon early termination of your Lease Agreement. A balance of $11,845.72 is due. This amount was calculated as described in your Lease Agreement. Less- Unearned Lease Charg? Less- Any Surpl?s from Vehicle Sale: Part A Subtotal {zero if negative} Add - Early Excess Mileage and Wear Charges: Add - Other Amounts Owed. Part C Less- Security Deposit Less- Other Funds Received * Amount owed C-MAC Base Monthly Payment times number of monthly payments not yet due $ 15,463.88 -$ 1,372.00 Part 8 +$ 0.00 +$ 1,562.34 -$ o.oo -$ 0,00 Part A. Su~lus fn~ Vehicle Sale LessVehicle- TerminationS~le Price ValuePlUs Any Insurance Settlement Surplus from Vehicle Sale [{1) - (2) if positive; zero if negative] lg,lO0.O0 15,291.50 $ 3,808.50 A Part B. Early Excess MileaaeandWear Cbe~ If there is a Loss f.romVe~icl~ Sale, you may also owe an early excess mileage and wear charge..Th~s charge ~s the lesser of the Loss from Vehicle Sale or the Total Excess N~leage and Wear Charge: Excess Mileage Charge { 0 miles at $ 0.15 per mile) +$ 0.00 Add - Excess Wear (None) +$ 0.00 Total Excess ~ileage and.Wear Charg? .{)3 $ 0.00 Loss from Vehicle Sale Jif (1)-(2) ~s negative] (4) $ Early Excess M~leage and Wear Charge [Lesser of {3) or {4)] 0.00 $ 0.00 B NOEL E GRIFFIE Page 2 July 30, 2001 020-6183-90966 Pa~ C. Other~B~unts ~ Past Due Monthly Payments (Incl. Sales Tax, etc.) $ 1,488.00 Add - Unpaid Fees and Taxes +$ 0.00 Add Cost of retaking and/or storing the vehicle (Includes Attorney's Fees of $0.00) +$ 0.00 Add - Unpaid Late Charges and Extension Fees +$ 74.34 Add Sales and Use Taxes on Excess Mileage and Wear Charges +$ 0.00 Add - Other Charges (None) +$ 0.00 Other Amounts Owed $ 1,562.34 C A balance of $11,845.72 is due. If you have any questions, please contact our office at 800-551-5377. Very tru)y yours, SMARTLEASE Department * Note! The amount listed above for Other Funds R~ceived can include any of the ~ollowlng amounts: additional security deposit, past due rentals paid, ~nsurance refund, odometer refund, anticipated payments, prepaid excess depreciation, prepaid excess odometer, or prepaid insurance deductible. WE ARE ATTEHPTING TO COLLECT THE NqOUNT OUR RECORDS SAY YOU OWE US NOW. ANY INFORMATION WEO6TAI# WILL BEUSEO FORTH ATPURPOSE. JJL LAVIN, COLEMAN, O'NEIL, RICCI, FINARELLI & GRAY By: Alysa Talarico, Esquire Identification No. 84512 510 Walnut Street Suite I000 Philadelphia, PA 19106 ATTORNEYS FOR PLAINTIFF GENERAL MOTORS ACCEPTANCE CORPORATION, 5700 Crooks Road - Suite 304 Troy, MI 48098 Plaintiff, NOEL E. GRIFFIE 801 Sandbank Road Mount Holly Springs, PA 17065 Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. 02-2915 CIVIL ACTION - LAW PRAECIPE TO WITHDRAW CIVIL ACTION COMPLAINT .~1'1'1t PREJUDICE TO THEPROTHONOTARY: Kindly withdraw Plaintiff's Complaint in the above-captioned Civil Action with prejudice. LAVIN, COLEMAN, O'NEIL, RICCI, FINARELLI & GRAY By: (~/~/0A lys a T311ar iF~co ~ Attorneys for Plaintiff, General Motors Acceptance Corporation