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Home My WebLink About07-0016 NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court LD. No. 43107 Brandon S. Williams, Esquire Supreme Court LD. No. 200713 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, Plaintiff Counsel For: GMAC : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. . ; NO. 07- 1& ~ --- I po.- KARTIC C. DASS, Defendant CIVIL ACTION - LAW: : ACTION IN REPLEVIN 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, 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 Telephone: (717) 249-3166 . NOTICIA Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por aboado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas 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 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. USTED DEBELLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIAT AMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VA Y A A LA SIGUlENTE OFICINA. EST A OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SIUSTED NO PUEDE P AGAR POR LOS SER VICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 Telephone: (717) 249-3166 NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court J.D. No. 43107 Brandon S. Williams, Esquire Supreme Court LD. No. 200713 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg P A 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: GMAC Dated: January 2, 2007 NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court LD. No. 43107 Brandon S. Williams, Esquire Supreme Court LD. No. 200713 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg P A 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, Plaintiff Counsel For: GMAC : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYL VANIA v. : NO. () JI - It.., GPv -r;:-. KARTIC C. DASS, Defendant : CIVIL ACTION - LAW : ACTION IN REPLEVIN COMPLAINT AND NOW comes Plaintiff, GMAC, by its counsel, Nauman, Smith, Shissler & Hall, LLP, to file the within Complaint based upon the following facts: 1. Plaintiff, GMAC, an entity organized under the laws of Delaware, having offices throughout the United States and having an office at 555 Business Center Drive, Horsham, Pennsylvania 19044. 2. Defendant, Kartic C. Dass (hereinafter "Defendant") is an adult individual presently residing in Cumberland County at 125 N. Enola Drive, Enola, PA 17025. COUNT I REPLEVIN 3. On October 23, 2003, Defendant entered into a Contract with Forbes Chevrolet, Camp Hill, PA 17011 (hereafter "Seller") for the purchase of a 2004 Chevrolet Cavalier, bearing Vehicle Identification Number IGIJC52F947216865 (hereinafter "Vehicle") for a net purchase price and finance charges in the amount of Thirteen Thousand Nine Hundred Twenty-Six Dollars and 001/00 ($13,926.00). A copy of the Contract is marked as Exhibit "A", attached hereto and its contents are incorporated herein by reference. 4. Defendant, pursuant to the aforesaid Contract, agreed, inter alia, to make sixty (60) installment payments in an amount of Two Hundred Thirty-Two and 10/100 Dollars ($232.10) each, commencing November 22,2003 and payable on the same day of each successive month thereafter, for a total obligation of Thirteen Thousand Nine Hundred Twenty-Six Dollars ($13, 926.00). 5. Under the Contract the Defendant granted the Seller or its assignee a security interest in the Vehicle and its proceeds. 6. Defendant, pursuant to the aforesaid Contract, agreed that in the event of default in any payment due under the Contract, or the failure to comply with any term or condition thereof, that the Seller of the aforesaid Vehicle may take possession of said property, including any equipment or accessories thereto, and for this purpose Seller may, in any lawful manner, enter upon the premises where the said property may be and remove same. 7. On or about October 23,2003, for good and valuable consideration, the said Contract was assigned by Seller to GMAC who succeeded to the rights and interest of Seller. GMAC, pursuant to the provisions of the Pennsylvania Motor Vehicle Code and the Pennsylvania Uniform Commercial Code, perfected its security interest in the Vehicle by properly notifying the Pennsylvania Bureau of Motor Vehicles to endorse upon the Certificate of Title for the aforesaid 2 Vehicle a notice of its encumbrance upon the aforementioned Vehicle and security interest therein. A copy of said Certificate of Title is marked Exhibit "B" and attached hereto. 8. Defendant has breached the said Contract in that Defendant failed to make the agreed- upon installment payments due. 9. Such defaults are continuing. 10. The present outstanding balance du.e GMAC from Defendant is in the amount of Six Thousand Six and 76/100 Dollars ($6,006.76), plus late charges. 11. GMAC sent Defendant a Notice of Default by letter dated November 16, 2006. A true and correct copy of said Notice of Default is attached hereto as Exhibit "C" and incorporated herein by reference. 12. Under the terms of the aforesaid Contract, Defendant agreed that in the event he defaulted in any payment due thereunder, or failed to comply with any of the terms or conditions of the Contract, and in the event it became necessary for the Seller or its assignees to institute a suit in replevin for the Vehicle, Defendant agreed to pay all costs of suit and any reasonable attorney's fees. 13. GMAC has made repeated demands that Defendant make the payments agreed upon, all to no avail. 14. The aforesaid Vehicle is presently in the control and custody of Kartic C. Dass, 125 N. Enola Drive, Enola, PA 17025. 15. Vehicles of this model and class have an average wholesale value of Six Thousand Eight Hundred and 00/100 Dollars ($6,800.00). 3 WHEREFORE, GMAC prays that this Honorable Court enter judgment in favor of GMAC and against the Defendant for: a. Possession of the 2004 Chevrolet Cavalier bearing Vehicle Identification Number 1 G IJC52F94 7216865 or in the alternati ve, the market value of the car in the amount of Six Thousand Eight Hundred and 00/100 Dollars ($6,800.00); and, b. Reasonable Attorney's fees and legal expenses incurred by reason of the institution of this action in replevin to repossess the aforementioned Vehicle; all as agreed to in the Contract dated October 23,2003. COUNT II BREACH OF CONTRACT 16. Paragraphs 1 through 15 above are incorporated herein by reference. 17. Pursuant to the Contract, Defendant has defaulted by his failure and refusal to pay installments in arrears, the sum of which (including late fees and unpaid charges) is Nine Hundred Thirty-Three and 04/100 ($933.04) at this time and increasing monthly. 18. At all times material to this case, GMAC has fully and satisfactoril y conformed to and complied with all terms and conditions required of it under the Contract. 19. Pursuant to the Contract, Defendant's default entitled GMAC to accelerate the contract and demand that the Defendant pay all that is owed at once, a late fee equal to 2% of the total amount of arrears, plus all other costs incurred in connection therewith. 4 20. To date, Defendant owes GMAC the approximate sum of Nine Hundred Thirty-Three and 04/100 ($933.04), plus late fees and costs. 21. The Contract provides that in the event the Defendant did not make the agreed upon monthly payments, resulting in a default under the Contract, and GMAC was required to employ an attorney, the Defendant agreed to pay reasonable attorney fees and Court costs. WHEREFORE, GMAC demands judgment in its favor and against the Defendant for: a. The sum of Six Thousand Six and 76/100 Dollars ($6,006.76), plus a late fee equal to 2% of the total amount of arrears and all other costs incurred in connection therewith; and b. Reasonable Attorney's fees and legal expenses incurred III connection with installments in arrears; and c. Any and all other relief which this court deems appropriate. NAUMAN, SMITH, SHISSLER & HALL, LLP P. Beneventano, Esquire Supreme Court I.D. No. 43107 Brandon S. Williams, Esquire Supreme Court LD. No. 200713 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg P A 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: GMAC Dated: January 2,2007 5 VERIFICA TION I, Elaine Sanchez, Semperian Agent for GMAC, being duly authorized to do so on behalf of GMAC, hereby make the following statements subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsifications to authority, and do state that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. zt~San~~ Elaine Sanchez Semperian Agent for GMAC Date: /"J-;) 9-00 ()~ ~~.,s~~~, . T{ ~-;;:--*^ C,'~!CIA~~~~~HI Y1 Cj;~ 'I, -::. ','\ . rd. GA RCEl,O~J .j ~, :~.v~,-,.1 NOT'!\HYfoUHlIC-i\f;.IZ.rJNi ~ . Zfttt?'r. >1, "'~/:/ Mt,RICOF'f\ C(JU'\FY'/{ i(~:;,"'~~;~;:L:~~';::;;E~:s,~:~~:".. . .;;.y 4105841678 PDP TITLE ADMINISTR 08:0517 a.m. 12 22 2006 5/8 RETAIL INSTALMENT SALE CONTRACT ~-'~~-_._'-'_, oealer~~._~.~~~~_ ~~-~'12-;;..o<l~.~] Buyer (and Co-Suyer) - Name and addrp.ss (include counly and zip code) . Creditor (Seller name and address) . KARTIC C DASS FORBES CHEVROLET, INC. 902 VALLEY STREET 3400 HARTlDALE DRIVE ENOLA PA 1702~ CAMP HILL PA 17011 YO:J. tho l3uyer {and CO-SIJyer, if any),may buy Ih~ V9hiC'iedeSCtibed below for cash or on Credit. By signing iiliSCOriiraCt. YOuchoose 10 buy the vehicle en credit ~r.:::ar the agreementll or, the front and I)ack of this c:onl'acl. You agree 10 pay us, Ihe Credilor. the Amount Financed al~d Finan:;e Charga dl;wrdirlg to Lila payment schedule shown below. New or Used Year NEW Nit CAVALIER Year 1998 Make PONT I At l~lJC~2F94721686S MbdeJGRANDn~. 9 Vehicle IdentiflCatfo~ ~ ~r "~"Prima Use for Which Purc~ased personal. fami!y, or household 0 agriCUltural o business 0 Make and Model Your trade-In I. a: - -- FEDERAL TRUTH.IN.LENDlNGDISCLOSURES lnIurllce. You ANNUAL FINANCE Amount TObII of Paymante T 0..1 hie Prloe this contract req who Is acceptabl PERCENTAGE CHARGE Financed The amount you · The total cost of other insurance t RATE The dollar The amount of wUI havu paid after your purchase on not buy other i The cost of your amount Ihe credit provided to you have made all credit, including approval process. credit as a yearly credit wOl COlit you or on your payments as your downpayment rate. you. behalf. scheduled. of $ F>11)(llIfl11 mm is If iUly Insurance from the namlld 9,2 % . 2796. 8L . 11129.28 $ 13926.88 $- 19926.00 terms and condit! Your Payment Schedule Win Be: Check the Inau Number Amount When Payments Or as Opt of Payments of Payments Ate Due Follows bm $ ~_'l~. tOl Monthly beglmlng t t j'~~ JIIIl' o Credit Ute: o Credlt Disabi - lItll Cbarg.. If a payment is not received in full within 10 days after itls due, you will pay a late charge. If the Premium: vehicle Is a heavy commercial motor vehicle, the charge will be 4% of the part of Ihe payment that Is late. If the Credit Ute $ vehicle Is off-highway business or farm equlpmen~ the charge will be 5% of the part of the payment thaI is late, Otherwise. the charge will be 2% per month of the part of the payment that Is late, figured based on a full Credit Dlsab calendar month for any part of a month that Is more than 10 days late. Pr.paym.at. If you payoff all your debt early, you may be entitled 10 a refund of part of the finance charge. N/A Security Internt. You are giving a security interest In the vehicle being purchased. :MdlflOIiII III'ormadan: See this contract for more information Including lnformatJon about nonpayment, . . default, any reqUired repayment In full before the scheduled date, prepayment refunds and security interest N/Q ., may buy the physical damage insurance ulres (see back) from anyone you choose e to us. You are not required to buy any o obtain credit. Your decision to buy or nsurance will not be a factor In the credit IS checked belOW. policies or certificates Insurance companies will describe the ons. ranee you want and algn below: Ional Credit InauranCfl. o Buyer n Co-Buyer lity (Buyer Only) ility $ N/A N/A (Insurance Company) ITEMIZATION OF AMOUNT FINANCED '1 Cash price (Including any aocesaorles, services, and taxes) '2 Total down a 8nt = If n five enter .0' and.... linQ 4H'bolow !..... Gross trade.ln $ . -payoff by sen'r S N/A ,i = net trade-in $ 2010. 00 _ + cash $ N/A ,.. + olher (describe) REBATE $ 4000. 00 3 Unpaid balance of cash prfr.e (1 minus 2) ____ _ ., ; 4 Other charges Including amounts paid to others on' your behalf (Seller may . keep part of these amounts.): A Cost of optional credit Insurance paid to the Insurance company or companies Ute Term N/A $ N/A Disability Term N/A $ N/A B Other Insurance paid to the insurance company (describe) N/A Term N/A C Official fees paid to govemment agencies . D Government taxes not included In cash price E Govemment Ucense and/or registration fees (Home Offrce Address) $ IG393~00 (1) Credit' life Insur~ aAd' C~edlt disability Insurance are not required to oblaln credit. Your decision to buy or not buy credit life insurance and credit disabUity insurance will not be a factor In the credit approval process. They will. nor bePtovi~ unless you sign and- agree to pay.the eXtra cost Credit life . insurance and credit disability insurance are for the term of this contract unless a different term for the insurance is shOwn below, $ 6000. 00 (2) $ 10J9:i. ee (3) Other Insurance. o N/A N/A Term $ N/A Type of Insurance Premium $ N/ A $ $ $ N/A N/A 623.70 N/A (Insurance Company) $ 6.00 F Government certificate of tiUs fees (Includes $ 5. 00securlty Interest reCOrding fee) $ 27.50 G Other charges (Seller must IdenUfy who Is paid and describe purpose.) to DEALER tor DOC FEE: $ 55.00 to COMM OF PA forTIRE TAX S 5.00 to for $ N/A to for $ N/A In rnMM n~ 00 f....nt.l I rM&:' &:'&:'&:' <t 14 IlIIlI (Home Office Address) I want the insurance checked above. X Buyer Signature 10/23/03 Date X CO-Buyer Signature 10/23/03 Date 4105841678 . . 1 Cash price (Includlng any acceuories, services, and taxes) 2 Total down a ent = If ne alive enter .0. and see line 4H below Gross trade-In S . -payoff by seller $ NI = net trade-in $ 2000. 0e + cash S N/A + other (describe) REBATE $. 4000.00 $ 6000.00 (2) 3 Unpaid balance of cash prl~~.!T1lnus.~)n___ ___-$ 10J95. 00 (3) 4 Other charges including amounts paid to oUlers on your behalf (Seller may keep part of these amounts.): A Cost of optional credit Insurance paid to the Insurance company or companies ute TermN/A $ N/A DIsabIlity Term N/A S N/A BOther Inaul8l1Ce paid to the Insurance company (describe) N/A Term N/A C Oftlclal fees paid to govemment agencies D Goven'ment taxes not included In cash price E Govemment license and/or registration fees P DP TITLE ADM INIS TR F Government certlllcate of title fees (includes $ 5. 08iecurlty Interest recording fee) $ G Other charges (Seller must identify who Is paid and describe PUIJ)088.) to DEALER forDOC FEE s loCO"'" OF PA forTlRE TAX s to for $ to for $ to COHH OF PA torON LINE FEE $ to DEALER for ON LINE FEE $ H Net trade- tn payoff to S Total other charges and amounts paid to others on your behalf 5 Amount flnariCed (3 + 4) 6 Finance charge 7 Total of payments - lime balance (5+6) 08:05:51 a m. 12 22 2006 6/8 $ 1639~. 00 (1) Credit life Insurance and credit dIsability Insurance are not required to obtain credit Your decision to buy or not buy credit life insurance and credit disability insurance will not be a factor In the credit approval process. They will not be provided unless you sign and agree to pay the extra cost. Credit Ufe Insurance and credit disability Insurance are for the lerm of Ihis conlract unless a different term for the insurance is shown ~erow, Other Inaurance. $ N/A o N/A ,_N/A Tenn Type of Insurance N/A $ $ $ Premium $ N/A N/A 623.70 N/A (Insurance Compan)'} . $ 6.00 (Home OffIce Address) 27.50 I want the insurance checked above. 55.90 5.00 N/A N/A 14.00 3.00 N/A X Buyer Signature 10/23/03 Dafe x Co-Buyer Signature 10/23/03 Date $ 73".20 (4) S 11129. 21 (5) $ 2796. 80 (6) $ 13926. 00 (7) ANY INSURANCE REFERRED TO IN THIS CONTRACT DOES NOT INCLUDE COVERAGE FOR PERSONAL LIABILITY AND PROPERTY DAMAGE CAUSED TO OTHERS. I" you do not meet your oontractual Obliptlona, you may loae your motor vehicle. tmw THIS CONTRACT CAN BE CHANGED. This contract contains the entire agreement between you and us relating to this contract. Any change to the ::XJntJ'act must be In 1{~ it. No oral changes are binding. Buyer Signs X . Co-Buyer Signs X . . If any part of this contract Is not valid, all other parts s~y yaUd. We may ~lIlyC)r refraln from enforcing any of our rtghts under this conlract without losIng them. For example. we may extend the time for making some payments without extending the time for making others. See back for other Important agreementa. Do not algn thl. contract on a Sunday. Notice to Buyer. You are entitled ,to an exact copy 01 the coritract you sign. Keep 10/23/03 Co-BuyerSlgns X " ) A- Date 10/23/03 Co.8uVlrllnd OIlier nen - A CO-buyer is a person who is responsible tor paying the entire deDt. An other owner Is a person whose name is on the lille 10 the vehicle but does not have to pay tho debt The co-buyer or other owner knows that we have a security Interest in the vehicle and consents to the security Interest Other owner signs here X Dale 10/23/03 Address CredllorSlgns X FORBES CHEVROLET, INCeale 10/23/03 ByX ~ -l/d,..-& ~ ~.Jou agree tp the terms of this cootra~t. You confirm that before YOU sianed this cpntdract, we g"ve,it ::i), YOP..1 and YOhU were fr.ee te) .take .t and review It. You confirm t a'l you receive a complete y .. ~I Efd-'n copy.W en s ea It. I } }uyer Signs X . Date 10/23/03 Co-Buyer Signs X AI I+- Dale 10/23/03 I Seller assigns ils interest in this contract to General Motors Acceptance Corporation (GMAC) under the terms of the GMAC Retail Plan agreement. I I ,. Assigned with recourse Assigned without recourse or with Ii ited recourse ORBES CHEVROLET, INC. SeUer By TIlle Seller ~1 09 PA 812003 (For Use in the State of Pennsylvania) (1 of 4) Notice: See Other Side ';opyrlght 2001 General Molors Acceptance Corporation. All Rights Reserved. -; ~ Title \. !li(;!t".\L 4105841678 POP TITLE AOMINISTR , OTHER IMPORTANT AGREEMENTS ,. .f-fV1. YOUR OTHER PROMISES TO US E' .. It the vehicle I. damaged, Clatroyed, or ml..lng. You agree to pay us all you owe under this contract even if the vehicle Is dama~, destroyed, or missing. ' b. U.lng the vehIcle. You agree nol to remove the vehicle from the U.S. or Canada. or to sell, rent, lease, or transfer any interest In the vehicle or this contract withOut our written permission. You agree not 10 expose the vehicle to misuse, seiZUre, confiscation, or involuntary transfer. " we pay any repair bHIs, storage bills, taxes, fines. or charges on the vehicle, you agree to repay \he amount when we ask for It c. SecurIty Inter..t. You give us a security Interest In: 1. The vehk:le and BII parts or goods Ins1aI\ed In it; 2. All money or goods received (proceeds) for the vehicle; 3. All Insurance, malnten&nCe, 58fVice, or other contracts we finance for you; and 4. All proce8da from Insurance. maintenance, ..rvlce, or other COlltracts we finance for you. this Includes any refunds of premiums or charges from the contracts. This secures payment of all you owe on this contract n also secures " your other aoreements In this contract. You will make sure the title :/ shows our security Interest (Hen) In the vehicle. ,n d. Inaurance you muat have on the vehicle. You agree to have physical damage Insurance covering loss or damage to the vehicle for the term of this contract. The Insurance must cover our interest In the vehicle. If you do not have this Insurance. we may, If W8 decide, buy physloal damage Insurance. If we decide to buy physical damage Insurance, we may buy Insurance that covers your Interest and our Interest In the vehlde. If we buy this Insurance, we will tell you the charge you muSt pay. The charge will be the premium for\t1e Insurance and a f1n~ charge at the highest rate the law permits... . If the vehicle Is lost or damaged, you agree that we may use any insurance settlement to reduce whal you owe or repair the vehicle. e. Wh.t hllJipena 10 returned Insurance,' ....lnten.nCe, """ce, or other contr.ot charge.. If we get a refund of iOSURlllC8, maintenance, service, or other contract chargeS. you agree that _ may apply the refund and the uneamed finance charges on the refund to what you OW8. 2. YOU MAY PREPAY IN FULL You may prepay all of your debt and ge1 a refund of part of the Finane'e . Charge. '.~ How we will calculete your Finance Chllrge refund. We will figure !he Ii refund by the Actuarial Method using the payment dates In this contract, except that you will pay at least $10 of total finance charges. We wi. not pay you a refund If It Is less than $1. =-. IF YOU PAY LATE OR BREAK YOUR OTHER PROMISES a. You may owe late Char,... You will pay a lale charge on eaCh lale payment as shown on the fronl. Acceptance of a late payment or late charge does not excuse your late payment or mean that you may keep making late payments. If you pay late, we may also take the steps described below. b. You may have to pay all you owe at once. If you break your promises (default), we may demand that you pay all you owe on this contract at once. Default means: 1. You do not pay any payment on time; 2. You start a proceeding In bankruptcy or one Is started against you or your property; or 3. You break any agreements in this contract. 08:06:103.m 1 2 22 2006 7/8 .... '") ~ \.~ ..,~'\. ~~.... e. We may take the vehicle from you. If you default, we may take (repo888$S) the vehicle from you If we do so peacefully and the law allows it If your vehicle has an electronic tracking devlce, you agree that we may use the device to find the vehicle. If we take the vehicle, anyaccessones, equipment. and replacement pWts will staY_with the -vehicle. If. any personal. items are in the vehicle, we may store them for you at your expense. If you do not ask for these Items back. we may dispose of them as the law allows. f. How you can get the vehlcl. blcJc If we take It. If we repossess the vehicle, you may get It back by paying the full amount you owe us (not Just pest due payments), InclUding expenses (redeem). We will taU you how much to pay to redeem. Your right to redeem enda when we sell the vehicle. If we IlIpossess the vehicle, we may, at our opllon, allow you to get the veh/de back before we sell It by paying all past due payments. late charges, and expenses (reinstate). g. W. will aell the vehicle " you do not get It blck. If you do not redeem, We wi sell the vehicle. We will send you a written notice of sale before selling the vehicle. We win apply the money from the sale. less allowed expeoses, to the emouot you owe. Allowed expenses are expenses we pay as a direct result of taking the vehicle, holding it, pr&palfng n for sale, and selling It ReaSonable attorney fees and court costs the law permlta are also aIlQW8(hxpenses.1f any money.ls left,(surplus), we Wi' pay It to you. If IY1<ltle, from the sale Is not enough to pay the amount you owe, you must pay the rest 10 us. If you do ~ pay this amount when we ask, we may charge you interest.at the t:lIghest lawful rate untfl you pay. h. What - may do about optlona' Ineurance, malnten.nce, aervlce, or other contracts. This contract may contain. charges for optional insurance, maintenance, service, or other contracts. If w. reposse88 'Ihe,vehlcle, we may claim 'benefits uncler these conti'acts and cancel them to obtain rafund. of unearned charges 10 reduce what you owe or repair the vehicle. If the YehIcIe I. a totallo!ss bec8uselt Is confiscated. . ' damaged, 0/" SfOIen, '.we may ClaIm benefits unde;tti8.. contracts 8nd cancel them to obtain refunclaof unearned chal'gea to reduce what you owe. 4. WARRANnES SELLER DISCLAIMS The following paragraph does not affect any wananties covering the vehicle that the vehlcle manufacturer may provide. The foRowing paragraph also does QQ1 apply at alllf you bought the vehicle primarily for parsonal, family, or household use. Un.... the Seller makea a written warr.nty, or enter. Into. service contrllC1 within 90 days from the date of this contract, the Seller make. no warrantl.., expre.. or Implied, on the vehicle. and there will be no Implied werrantlea of merchantability or of f1tn... for a particUlar purpose. 5. Uaad Car Buyer. Guide. The Information you ... on the window form for thla v.hlcle la part of thl. contract. InformatIon on the window form ovarrld.. any contrary provision. In the contract of ..... Spanish Translation: Gura para comprador.. de vehrouloe UNdo.. La InformacIOn que ve en ., formularlo de I. ventanllla par. e.te vehfculo forma parte del prea.nt. contrato. La Inform8elftn .....1 '...,...,,1.,... _ J. .__0__1"_ "'_,_ 4105841678 PDP TITLE ADM INISTR cnarge at me rngnest rate the law pennits. If the vehicle is lost or damaged, you agree that we may use any , insurance setUemeot to reduce what you owe or repair the vehicle. e. What happeM to returned Insurllnee, maintenance, service, or other oontraot charg... If W8 get a refund of Insurance, maintenance, service, or other contract charges. you agree that we may apply the refund and !he uneamed finance charges on the refund to what you owe. 2. YOU MAY PREPAY IN FULL You may prepay all of your debt and get a refund of part of the Finance Charge. How we will c.lcu.... your Fln.nce Charge refund. We wlU figure the refund by the Actuarial MethOd using the payment dates in this contract, except that you will pay at least $10 of total finarlce charges. We win nol pay you a refund If It Is less Ihan $1. 3. IF YOU PAY LATE OR BREAK YOUR OTHER PROMISES .. You may owe late charge.. You will pay a late charge on each rate payment as shown on the front. Acceptance of a late payment or late charge does not excuse your late payment or mean thaI you may keep making late payments. If you pay late, we may also taKe the steps descr1b8d below. b. You may have to pay all you owe at one.. If you' break your promises (default), w8,I'I'IaY demand that you pay all you owe on this contract at once. Default means: 1. You do not pay any payment on Uma; 2. You start a proceeding In bankruplcy or one Is Slaned against you or your property: or 3. You break any agreements In this contract. In figuring what you owe, we will give you a refund of part of the Finance Charge as If you had prepaid In fun. c. You may have to pay collection coata. " we hire an attorney to collect what you owe. you will pay the reasonable attorney's fee and court costs. as the law allows. d. Summary Notlea A-uardlnSl Prepayment and Relna"tement. You can prepay all of your debt and get a refund of the Finance Chatge. If you default and we repossess the vehicle, we may, at our option. allow you to get the vehicle back before we &en It by paying ail pul due payments, late c:harges. and expenses(relnstate). 08:06:54 a.m. 1 2 22 2006 8/8 h. What we may do about optional In.urenee, maintenance, aervlce, or other contracta. This contract may contain charges for optlona Insurance. maintenance, service, or other contracts. If we repossess the vehicle, we may claim benefits under these contracts and cancel them 10 oblain refunds of unearned charge. to reduce what you ow. 01 repair the vehicle. If the vehicle Is a tota/Ioss because It Is confiscated. damaged, or stolen, we may claim benefits uncler Ihese contracts and cancel them to obtain refunds of unearned charges to reduce what you owe. 4. WARRANTIES SELLER DISCLAIMS The following paragraph does not affect any warranties covering the vehicle that the vehicle manufacturer may provide. The following paragraph also does !!21 apply at all if you bought the vehicle primarily for personal, family, or household use. Un I... the Seller makes a written warranty, or anters Into a service contract within 90 day. from the date of thla contract, the Seller make. no WlII'...ntle., 8xpre.. or Implied, on the vehicle, and there will be no ImpUed warranllea of merchantability or of fltn... for a particUlar purpose. 5. u_ C. Buy.... GuIde. The Information you ... on the window form for this vehicle Ie part of thla contract. Information on the window form overrld.. any contrary pt'ovlalon. In the contr.:t of ..... Span"" Tranalatlon: Gufa pwa compradorea de vehlculoe uaados. La InformacIOn que va en eI formularlo de .. ven"nU" patII .... vehfculo forma pa.... del prenme conU'ato. La Informacl6n del formu"rfo de.. ventanll" deja aln .fecto tode dlapoelol6n en contrarlo con"nlde en .. contralO de ven... 8. APPUCABLE LAW Federal law and Pennaylvanla law apply to this contract HOTlCE: ANY HOLDER OF THIS CONSUMER CREDIT CONtRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELL~ OF, GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. PDP TITLE ADMINISTR 08:03:40 a,m. 1 2 22 2006 I I I C~~TIFICATE OF TITL~,FOR~ V.~.t!JS:LE ,OS? 033D33lfOODlib17&.~O];::' : '~Gl~~~~~e~,' ,. :,lj:.'..c~!l~~.r::.#,~~tl~~:_:.',..._,:t..._~,~~~~~!,~~~,.., ~i~~;}it;;;~ff.ii=!r;::~i_:.--:cz~ :~p~;~, 'dr;, !.l~~?tE~:l. . .. __ afA1\II D . AClUAI. IoIIU!.t8E , . IIILIMIE I!XCUD& _ IlEOW<<:Al. LIlQ'I I. NCJI"". ~..,.., ,. NOr,.. M:1UOI. ~, T__ 4.~_~~ mu_ A . __ \III1ICU". '~!_~,. t ...-..~ . 'C. .~,P. ._ .::f::,ft . ~!.I",* ~, "~~:I~' ... .. . :<<"~'I' ~OASS ' ",..a.r, VAJ.,lE' ST. ::~'M)(A . PI., '17025, f.:,......',!fi:11.j.~.',:.'.::.'.'~...,..,: . ::',<:t:: ~ {:~:< ',.1,.", I "\,;"'d_ , ':r,' '. ....~. .. ."N-', ~ .~~ . ,.". , .::.. '. .~ > .' " ,~ 8E~ U1!N FAYClI\ OfF: MJTHOIlQBl ~AT1YE .' ',;L.~:~ - _ --*iri~~';"~.... ~.. : L. ..., ==::tll'li!l......... .. TIle .. lie -- 01: -. ',. v..~ ~ 1* '. ~~~;/. ': ....,.... ':'~,r",' ' Sl!OONlI. Ll!N ~ 0.\111 .y. AUn<<lfllZED R9flU&NTATMI , ~\::.~ 'GMAC ' 'p 0 80X 61'" COCKEVSVIlLE NO i!lDlO' ( ALLEN OIIEHLER' -.. "" .. -...... ., .' . -~ . . ImRJ CITY STATe . V FINAHCW. INIITITlJTION HUlMEA .Jo 11 :zNO UEH 0.\ n: I ,) I mE) L"NHOLDliR ') J STll~ SkVtATUFIf Qlf APPUCAHT 0fII AullOltlEU $IOHEA .) ,CITY STAT! ZIP , 0 ! - INSTJT\JTIOfI NUMBEA 3/8 + LJ lA [J 'B-S - 4105841678 POP TITLE AOMINISTR 08:04:23 a.m. 12222006 . (TYP.E OR PRINT) CertJficale of Tille must.be aubmlttlld wilhln 20 days, unless the PUlChaser l8 a registered dealer holding the vehicle few resale, '~+ WARNING. FEDERAL AND STATE LAWS REQUIRE THAT YOU STATE THE MILEAGE (ODOMETER READING) IN CONNECTION WITH THE TRANSFER OF OWNERSHIP. FAILURE TO COMPLETE OR PROVIDING A FALSE STATEMENT MAY RESULT IN FINES AND/OR IMPRISONMENT. 4/8 :~ .~ IMPORTANT NOTICE Please be advised that In lieu of notarization on thIs form. verification of a person's signature by an I.sulng agent who Is flcensed as a vehicle dealer by the Pennsylvania State Board of Vehlcl. Manufacturer.; Dealers and Salespersons. or Its employee Is acceptable. The signature and prlntect name of the IssuIng agent or the Issuing agent'. employee. date of verification, the ISSUing agentJIlcensed d.al....hlp.s deal.r Identifi- cation number (DIN) and business na~. must be listed In the space provided for notarization. Vehlcl. seller and purchaser must sign only. In the presence of an officer .mpowered to administer oaths or an 'authorized agent as Identified above. ,. . ~?IC~[~:':'~l'ti' (l;~. "'0' . '. ---. .......~... O,.'.HaI' .....':'. "'. , . ""'...---., ' . ....,.".''''', " ...............................""w...-_.... ~'iiJl.. : .......11I .............._1lIIIi& . , t. " ~..;r.~ "t.<~~' ". 0" 'l:::.:;".;' ;,~ ',~::'~''ff.. F';'; -~~:~*::~.~::'~.~.";'4 : -' .' . ..-.:~ ", ':~,';' '-;:~'}'~~ ::. .; '-..j, STATf ZP SUIl8CRI8ED AND SWORN TO BeFORE ME: ~~ eCf.l ~ ~ ~~ C. OCHECK Hi:RE IF APPLICATION FOR DEALER TTTLE';AND QOMPLErE SEcn~ D. nTUNQ FEES' ~a.F.llQl(l{l ~....,llUJ."", .~Ul..." . ....,. . . Attorneys At Law Please reply to P. O. Box 840 Harrisburg, PAl 71 08-0840 Guy P. Beneventano. Esquire Guyobenny@nssh.com November 16, 2006 Via Certified Mail No. 7005 0390 0002 9075 9705 and Re2Ular Mail Mr. Kartic C. Dass p.o. Box 245 Enola, P A 17025 In re: GMAC Account #020-9047-20404 2004 Chevrolet Cavalier Dear Mr. Dass: Please be advised this office represents GMAC and in that connection, your overdue and delinquent account has been referred to this firm for advice and the appropriate action if not resolved promptly. This letter is an attempt by GMAC to collect a debt, and any information obtained from this letter will be used for that purpose. GMAC has advised you that under the terms of a Retail Installment Sale Contract, you are delinquent in paying the August, 2006, payment in the amount of $204.26, and the September and October, 2006, payments in the amount of $232.10 respectively, plus late charges in the amount of $27.84 for a total delinquency of $696.30. Unless you dispute the validity of the debt described above within seven (7) days of the date of this letter. we will assume that the debt is valid. If you notify us within seven (7) days that the debt is disputed, we will obtain further verification of the amounts owed and mail such verification to you. Pursuant to the terms and conditions of the Retail Installment Sale Contract with GMAC that you signed, you are hereby called upon to cure the default by paying the sum of $696.30 within seven (7) days of the date of this notice. Please be advised that GMAC reserves the right to pursue all of its rights and remedies as indicated by the Retail Installment Sale Contract, which may include repossession of the vehicle. You are also called upon to pay the attorneys' fees incurred by GMAC in connection with your default. Specific information concerning these attorneys' fees will be provided to you after GMAC's receipt of the total delinquency. Superior analY0is, Effective 0olution0. S incel871, Nauman Smith Shissler & Hall. LLp. 200 North 3rcl Street. Harrisburg. PA 17101 . 717.23().:~O1O. fax: 717,234,HJ25. www,nssh,cum Kartic C. Dass November 16,2006 Page 2 If you fail to cure the default, GMAC will declare the entire amount you owe under the Contract IMMEDIATELY DUE AND PAYABLE. YOU MAY CONTACT GMAC FOR THE TOT AL AMOUNT DUE. If you wish to correspond to GMAC directly please contact: GMAC Attn: J. Buffington P. O. Box 410688 Charlotte, NC 28241 You may also call J. Buffington at GMAC at 704-357-7084. If you do not dispute the validity of the debt or otherwise promptly make the delinquent payments, then, GMAC will exercise its remedies, including (but not limited to) filing a lawsuit against you for the repossession of the 2004 Chevrolet Cavalier and for breach of contract. If GMAC is forced to file a lawsuit against you, it will seek payment of the entire amount you owe under the Contract. I trust you will act to pay the delinquent payments, and thus avoid the expense and embarrassment of such litigation. Respectfully yours, /7~" ~Guy P. Beneventano GPB/sb cc: J. Buffington GMAC r, ,....., ~ (.~- ~-:::::J "- c,::;, 0 ....,.,.,J -I) <- S! r ~ .""t:... ~::::: rq 2J (3 r~"'" , rr:! ()..l .h f\:J ......... ::" ""1 ,q -~... ~ Ei' - ;, .J -. t ~ '. s: ~ v-\ .r.- (.n ."J::J 9'\ "< ~ NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court I.D. No. 43107 Brandon S. Williams, Esquire Supreme Court LD. No. 200713 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg P A 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, Plaintiff Counsel For: GMAC : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYL VANIA : NO. 07, It., v. : CIVIL ACTION - LAW KARTIC C. DASS, Defendant : ACTION IN REPLEVIN PRAECIPE FOR ENTRY OF APPEARANCE Please enter the appearance of Guy P. Beneventano, Esquire, and Brandon S. Williams, Esquire, as Attorneys for GMAC, the Plaintiff in the above captioned case. NAUMAN, SMITH, SHISSLER & HALL, LLP P. Beneventano, Esquire Supreme Court LD. No. 43107 Brandon S. Williams, Esquire Supreme Court LD. No. 200713 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: GMAC " Dated: January 2, 2007 -- - co ~ = = "-' '- ~ -.." '""""'- o -n ~"'n ~ t.~; , -(.,r-,-: ~~) C...""J '-""),L. :1, ~7_j ;" " \ -..'--. ~f;; '"'" I N ::s: -,,;... ." NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court LD. No. 43107 Brandon S. Williams, Esquire Supreme Court LD. No. 200713 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg P A 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, Plaintiff Counsel For: GMAC : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, P A v. : NO. 07-16 Civil Term Defendant CIVIL ACTION - LAW ACTION IN REPLEVIN KARTIC C. DASS, PRAECIPE TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff, GMAC, and against Defendant, Kartic C. Dass, for failure to plead to the Complaint in this action within the required time. The Complaint contains a Notice to Defend within twenty (20) days from the date of service thereof. Defendant was served with the Complaint on January 5, 2007, and an answer was due on or before January 25, 2007. Attached as Exhibit "A" is a copy of Plaintiffs written Notice ofIntention to File Praecipe for Entry of Default Judgment which I certify was mailed by regular mail to the last known address of Kartic D. Dass, which is at least ten (10) days prior to the filing of this Praecipe. Please enter judgment pursuant to Pa.R.C.P. 103 7(b), 1071 and 1084 for possession of a 2004 Chevrolet Cavalier, VIN 1GIJC52F947216865, and for $6,006.76, plus costs, for failure of the Defendant, Kartic C. Dass, to file an Answer to Plaintiff s Complaint within twenty (20) days of service thereof. NAUMAN, SMITH, SHISSLER & HALL, LLP ,~-~ P. eneventano, Esquire upreme Court LD. No. 43107 200 N. 3rd Street, 18th Floor ~ P. O. Box 840 Harrisburg P A 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 Counsel For: GMAC Dated: February 9,2007 Exhibit "A" N.aUUlaIl Smitll Attorneys At Law Please reply to: P. O. Box 840 Harrisburg, PAl 7108-0840 Guy P. Beneventano, Esquire Guypbenny@nssh.com January 29, 2007 Kartic C. Dass 125 N. Enola Drive Enola, P A 17025 RE: GMAC v. Kartic C. Dass No. 07-16 Civil Term GMAC Acct. No.: 020-9047-20404 Our File No.: 9768-1440 Dear Kartic C. Dass: Enclosed herewith is our Notice to you that you are in default because you have failed to take action in the above-captioned matter. Unless action is taken within ten (10) days, we will file with the Prothonotary of Cumberland County our Praecipe to Enter Judgment. Sincerely yours, . A72?~~ ~---iuy P. Beneventano GPB/sm Enclosure cc: GMAC Superior analysis. Et't'ective solutions, Since Jil7J \Iauman Smith Shissler & Hall, LLP · :200 \Iorth 3nj Strr~et 9 I1mrisburg. PA J7101 .717.236.3010' fax: 717,:234,1025. www,l1ssh,com NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court I.D. No. 43107 Brandon S. Williams, Esquire Supreme Court I.D. No. 200713 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg P A 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, Plaintiff Counsel For: GMAC : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, P A v. : NO: 07-16 Civil Term KARTIC C. DASS, Defendant CIVIL ACTION AT LAW IMPORTANT NOTICE TO: Kartic C. Dass DATE OF NOTICE: January 29, 2007 YOU ARE IN DEF AUL T 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 (l 0) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland COWIty Bar Association 32 S. Bedford Street Carlisle, P A 17103 Telephone: (717) 249-3166 NAUMAN, SMITH, SHISSLER AND HALL /.~ ? K ~, By: /?~ /. ..,.1_ _______ (~ G6yP. Beneventano, Esquire Supreme Court ID# 43107 200 North Third Street P.O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-30 I 0 Facsimile: (717) 234-1925 Counsel for: GMAC Date: January 29, 2007 .. CERTIFICATE OF SERVICE I hereby certify that on the date listed below I served a copy of the foregoing Notice by depositing in U.S. First Class Mail a copy of same addressed as follows: Kartic C. Dass 125 N. Enola Drive Enola, P A 17025 - ~j)'l,,[ (~I j(--f Sherry A. May; Paralegal to // Guy P. Bene-J'entano, Esquirk' Dated: January 29, 2007 (; ;:c) (J ~ ~ ~ -0 ~ ~ ,,::... . ~ ;~ Cl- ~ 0 ~ .-n ~Vi\ ~ 0 "-:J' .-f\ - ~e - 'O~ ~ W ~ (.;0 ;F; 0> ~ .-/ ~. A......~ , - ec:' ~ ~1S1d ~... .,,~~ ...0 .~; 7:') 5 ~ ~ ~ C? ::;::;.\ ~ y'C: ~ VJ J ~ tv !:f ~ 2- 0 ~ (':> ..14- 1 1t- -t) . 6 - CJ.J -J ~ "-' r ...p 0 -... f- ~ - , r - " ~ NAUMAN, SMITH, SHISSLER & HALL, LLP Guy P. Beneventano, Esquire Supreme Court LD. No. 43107 Brandon S. Williams, Esquire Supreme Court LD. No. 200713 200 N. 3rd Street, 18th Floor P. O. Box 840 Harrisburg PA 17108-0840 Phone: (717) 236-3010 Fax: (717) 234-1925 GMAC, Plaintiff Counsel For: GMAC : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 07-16 Civil Term KARTIC C. DASS, Defendant ACTION IN REPLEVIN NOTICE OF JUDGMENT TO: KARTIC C. DASS You are hereby notified that on :r ~ c. ~ 1..1 has been entered against you in the above captioned case: , 2007, the following judgment Judgment in favor of Plaintiff, GMAC, and against Defendant, Kartic C. Dass, as follows: Possession of the 2004 Chevrolet Cavalier bearing Vehicle Identification Number IGIJC52F947216865, and for judgment in the amount of $6,006.76, plus interest, late fees, reasonable attorney fees, costs of collection, costs of repossession, costs of storage and all other charges as provided in the contract or as provided by law, and increasing monthly. Judgment was entered pursuant to Pa. R.C.P. 1047 for failure of Kartic C. Dass to file a response to GMAC's Complaint twenty (20) days of service thereof. f~ I hereby certifY that the proper person(s) to receive this notice under Pa. R.C.P. 236 is: Kartic Dass 125 N. Enola Drive Enola, P A 17025 , , ~ NAUMAN, SMITH, SHISSLER & HALL, LLP Rj?~ y P. Bene~ntano, Esquire Counsel for GMAC Dated: February 9, 2007 CASE NO: 2007-00016 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC VS DASS KARTIC C RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN DASS KARTIC C DEFENDANT was served upon , at 1351:00 HOURS, on the 5th day of January at 125 N ENOLA DRIVE ENOLA, PA 17025 KARTIC C DASS by handing to a true and attested copy of COMPLAINT - REPLEVIN the 2007 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this of 18.00 13.20 .00 10.00 .00 41 .2 oj ~"~,, 1#': l)~ day So Answers: r~~<~ R. Thomas Kline 01/08/2007 NAUMAN SMITH SHISSLER & HALL BY:~~ DepU~Sheriff A.D.