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Home My WebLink About02-3562IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant COMPLAINT IN CIVIL ACTION 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583687 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant Civil Action No. COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND 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 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 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant Civil Action No. COMPLAINT AND NOW COMES, Plaintiff, First Select, Inc., by and through its counsel, WELTMAN, WEINBERG & REIS, CO., LPA., and hereby files this Complaint against Defendant, Jennifer K. Schmidt, and, in support thereof, Plaintiff avers as follows: 1. The Plaintiff, First Select, Inc., is a corporation with its principal place of business located at 4460 Rosewood Drive, Pleasanton, CA 94588. 2. Plaintiff is the owner of this account, which is the subject matter of this action. 3. Defendant is an adult individual residing at 208 Louis Lane, Enola, Cumberland County, Pennsylvania 17025. 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of June 11,2002, in the amount of $5,306.93. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Jennifer K. Schmidt individually, in the amount of $5,306.93 with finance charges thereon at the rate of 6% per annum from June 11, 2002, plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#: 02583687 · ' ********* RON MCGHEE ********* CURRENT PAYMENT 0 .00 MIN PYMT 106.00 PURCHASE 0 .00 CASH ADV 0 .00 CREDITS 0 .00 MISC CHG 0 .00 INS FEE .00 LATE CHG .00 OVRL FEE .00 PURC F/C .00 CASH F/C .00 LIMIT 1.00 BALANCE 5,306.93 TCSI 001 CODE IHB ACCT 4168100022541005 CYCLE 11 AGENT 0372 ( 12 MONTH HISTORY :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: SCREEN SELECTION ( 1 2 1 4 ) => SCHMIDT JENNIFE (01) 06/11/02 (02) 05/13/02 (03) 04/11/02 0 .00 106.00 0 .00 0 .00 0 .00 0 .00 .00 .00 .00 .00 .00 1.00 5,306.93 0 0 .00 .00 212.00 212.00 0 0 .00 .00 0 0 .00 .00 0 0 .00 .00 0 0 .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 .00 1.00 1.00 5,306.93 5,306.93 (04) 03/11/02 0 .00 212.00 0 .00 1 5,306.93 0 .00 0 .00 .00 .00 .00 .00 .00 1.00 5,306.93 VERI~FICATION The undersigned does hereby verif~ subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is Jeff Swan, Designated Agent of First Select Inc., plaintiff herein, that he 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 his/her knowledge, information and belief. SHERIFF'S RETURN - C~SE NO: 2002-03562 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT INC VS SCHMIDT JENNIFER K NOT SERVED R. Thomas Kline , Sheriff according to law, says, that he made a diligent the within named DEFENDANT , to wit: SCHMIDT JENNIFER K , who being duly sworn search and inquiry for but was unable to locate Her in his bailiwick. COMPLAINT & NOTICE He therefore returns the the within named DEFENDANT NOT SERVED , as to , SCHMIDT JENNIFER K ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, UNABLE TO SERVE PRIOR TO EXPIP3tTION. Sheriff's Costs: Docketing 18.00 Service 31.05 Affidavit .00 Surcharge 10.00 .00 59.05 So answErS ~. THOMAS KLINE SHERIFF OF CUMBERLAND COUNTY WELTMANWEINBERG REIS 08/27/2002 Sworn and subscribed to before me this ~ day of ~ ~2~0 .~ A.D. Prot%lc/notary ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. No. 02-3562 PETITION FOR ALTERNATE SERVICE JENNIFER K. SCHMIDT Defendant 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 Pittsburgh, PA 15219 (412) 434-7955 WWR#02583687 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant No. 02-3562 PLAINTIFF'S PETITION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Weltman, Weinberg & Reis Co., L.P.A. and petitions this honorable court to enter an Order allowing service upon Defendant, Jennifer K. Schmidt, by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid, addressed to 208 Louis Lane, Enola, PA 17025, averring in support of the following: 1. On or about July 25, 2002, pursuant to Defendants breach of an Agreement entered into between the parties, Plaintiff filed a Complaint in Civil Action against Defendant to recover the unpaid balance on the Agreement due Plaintiff from Defendant in the amount of $5,306.93 together with continuing interest thereon at the rate of 6% per annum and costs. 2. When the Sheriff of Cumberland County, Pennsylvania, attempted to make service of Plaintiff's Complaint on Defendant, the Sheriff was unable to do so, indicating that numerous attempts were made, unable to serve, as evidenced by the Sheriff's return, a true and correct copy of which is attached hereto, marked Exhibit "1", and made a part hereof. 3. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendant. 4. Pursuant to Plaintiff's request for information, the United States Postal Service confirmed Defendant's physical address of 208 Louis Lane, Enola, PA 17025, a true and correct copy of Plaintiff's Postal Request is attached hereto and marked as Exhibit "2", and made a part hereof. 5. Plaintiff contacted the Cumberland County Directory Assistance, a representative from which could not provide a current address for Defendant of 208 Louis Lane, Enola, PA 17025. 6. Plaintiff contacted the Cumberland County Voter Registration office, a representative from which indicated that Defendant is not registered to vote in Cumberland County, and therefore could confirm an address. 7. Plaintiff received vehicle information from the Depadment of Transportation, which shows that a vehicle is registered to Defendant at the current address of 208 Louis Lane, Enola, PA 17025. A true and correct copy of the vehicle record is attached hereto, made a part hereof and marked Exhibit 8. Based upon the foregoing, Plaintiff believes and therefore avers that Defendant, Jennifer K. Schmidt, is attempting to avoid service of process in the above-captioned matter and Plaintiff therefore seeks an Order of Court, pursuant to Pennsylvania Rule of Civil Procedure 430, granting Plaintiff leave to serve its Complaint on Defendant by alternative means. WHEREFORE, Plaintiff respectfully requests this Honorable Court permit Plaintiff to serve Defendant, Jennifer K. Schmidt, with the Complaint in Civil Action by permitting the Plaintiff to mail a copy of the Complaint in Civil Action to Defendant at her last known address being 208 Louis Lane, Enola, PA 17025 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. William T. Molczan~E'squire PA I.D. ff47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Building 436 7th Avenue Pittsburgh, PA 15219 (412) 434-7955 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff No. 02-3562 VS. JENNIFER K. SCHMIDT Defendant AFFIDAVIT Before me, the undersigned authority, personally appeared William T. Molczan, being duly sworn according to law deposes and says that he is an attorney for the Plaintiff, authorized to make this Affidavit; that he, and not the Plaintiff makes this affidavit because he, and not the Plaintiff has first hand knowledge of the facts set forth in the foregoing Petition for Alternate Service which are true and correct My ~ion Ex~r~ Jd¥ 15, 2006 to the best of his knowledge, information and belief. AWt Itlol Irann~ y'l'fo rM ~ll:~na .t~ Sworn to and subscribed~/ore me this /~-_~) dayof_~,~~,~02. SHERIFF'S RETURN - NOT SERVED 'CASE NO: 2002-03562 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST SELECT INC VS SCHMIDT JENNIFER K R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: SCHMIDT JENNIFER K unable to l~cate Her in his bailiwick. but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT NOT SERVED , as to , SCHMIDT JENNIFER K ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, UNABLE TO SERVE PRIOR TO EXPIRATION. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 31 05 00 10 00 00 59 05 R~. THOMAS KLINE SHERIFF OF CUMBERLAND COUNTY WELTMANWEINBERG REIS 08/27/2002 Sworn and subscribed to before me this day of A.D. Prothonotary WELTMAN, WEINBERG & REIS Co., LP.A. ATTORNEYS AT LAW 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 412.434.7955 www.weltman.com WILLIAM T. MOLCZAN 412.434.7955 Fax 412.434.7959 wmolczan~weltman.com CLEVELAND 216.685.1000 COLUMBUS 614.228.7272 CINCINNATI 513.723.2200 DETROIT 248.362.610o Postmaster ENOLA, PA 17025 September 10, 2002 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: JENNIFER K SCHMIDT Address: 208 LOUIS LANE ENOLA, PA 17025 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.4,4a and b. 1. Capacity of requester: William T. Molczan, Esquire1 Attorney for Plai~rltiff, FIRST SELECT, INC. 2. Statute or regulation that empowers me to serve process · NIA 3. The names of all known parties to the litigation: FIRST SELECT, INC. vs. JENNIFER K SCHMIDT 4. The Court in which the case has been or will be heard: Court of Common Pleas of CUMBERLAND 5. The docket or other identifying number if one has been issued: 02-3562 The capacity in which this individual is to be served: Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTIAN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFOMRATION FOR ANY PURPOSE OTHER THAN THE SFRVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OF (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). September 10, 2002 Page 2 I certify that the above information is [rue and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Si~'~ature - - - WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Address Amanda Dunham Printed Name Pittsburgh, PA 15219 City, State, ZIP Code FOR POST OFFICE USE ONLY BOXHOLD ER'S POSTMARK Not known at address given. Moved, left no forward address. No such address. No change of address on file Good as Addressed XXX PLEASE INDICATE PHYSICAL ADDRESS NEW ADDRESS or NAME and STREET ADDRESS WWR¢/~2583687 12500~ O~NER PENNSYLVANIA DEPARTHENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 10/02/02 PAGE I 02275070~000156 JENNIFER K SCHMIDT 208 LOUIS LANE P 0 BOX 129 ENOLA PA 17025 LESSEE : NONE TITLE NUHBER TAG NUHBER VIN : 5~755780 : DFL1581 : JF2AGSSB2KE800171 HAKE HODEL , RENENAL PREVIOUS TAG LIENS STOPS : SUBARU : G~D : 02125108~000706 001 : NO : NO TITLE BRAND INFORHATION NO TITLE BRANDS EXIST FOR THIS TITLE TITLE DATE : 06/OZ/O0 REGISTRATION EXPIRY DATE= 05/05 BODY TYPE : CP ODOHETER READING : 1~8,259~ ~ACTUAL HILEAGE DUPLICATE TITLE COUNT : 0 VEHICLE YEAR : 1989 STOLEN DATE 0EC 2 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant No. 02-3562 ORDER OF COURT AND NOW, to-wit, this ~' ~ day of </'~,,,d,~,,,., ,200~, upon / / consideration of the foregoing Motion for Service of the Complaint in Civil Action Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendant, Jennifer K. Schmidt, by permitting the Plaintiff to mail a copy of the Complaint in Civil Action to the Defendant at her last known address being 208 Louis Lane, Enola, PA 17025 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. BY THE COURT: WWR#02583687 01.-09." IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant No. 02-3562 PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHAILF 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#02583687 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant Civil Action No. 02-3562 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. William T. Molczan, Esqu~e PA I.D. #47437 ~ WELTMAN, WEINBERG & REIS CO., LP.A. 2718 Koppers Building 436 Seventh Aw~nue Pittsburgh, PA 15219 (412) 434-7955 WWR #02583687 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant No. 02-3562 CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT 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#02583687 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff No. 02-3562 CIVIL TERM VS. JENNIFER K. SCHMIDT Defendant AFFIDAVIT OF SERVICE OF COMPLAINT Before me, the undersigned authority, personally appeared William T. Molczan, Esquire, who, being duly sworn according to law, deposes and says that on January 23, 2003, he did cause to be sent to Defendant, Jennifer K. Schmidt, Plaintiff's Complaint by Certificate of Mailing Postal Form 3817 and on January 23, 2003, he did cause to be sent to Defendant, Jennifer K. Schmidt, Plaintiff's Complaint by Certified Mail, Return Receipt requested, directed to the Defendant at her last known address of 208 Louis Lane, Enola, PA 17025. True and correct copy of Plaintiff's Certificate of Mailing PS Form 3817 is attached hereto, marked as Exhibit "1" and made a part hereof. Furthermore, true and correct copy of Plaintiff's Receipt for Certified Mail is attached hereto, marked as Exhibit "2" and made a part hereof. As the Order of Court states, service is deemed to be perfected as of January 23, 2003, the date of mailing. WELTMAN, WEINBERG & REIS CO., L.P.A. 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 Sworn to and sub~sc,~ri!~d before,_~e ~;his h (i)"I-A~Y ~/[IC ' WWR#02583687 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAll.., DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: ., ,o o · ~ .~,- PittM3u~h, PA 15219 / PS Form 3817, January 200.1 . OFFICIAL USE ~ Postage $ r~" Certified Fee B"' Postmark Return Receipt Fee Hem ~--~ (Endoreemalt Required) I"1 Restricted Deliver/Fee I'-1 (Endomement Required) Total Postage & IS ~',~pL'HO.; /'~0 t" ":g" '/ ...... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant No. 02-3562 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT 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#02583687 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 FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant Civil Action No. 02-3562 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, Jennifer K. Schmidt, above named, in the default of an Answer, in the amount of $5,534.62 computed as follows: $5,306.93 Amount claimed in Complaint Interest from 6/11/02 to 2/27/03 at the contract interest rate of 6% per annum $227.69 TOTAL $5,534.62 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. pWiAIIi.a~. Tfl.~74r4r~l~zan, Esquiy WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583687 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2601 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 208 Louis Lane, Enola, PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant Civil Action No. 02-3562 CIVIL TERM IMPORTANT NOTICE TO: Jennifer K. Schmidt 208 Louis Lane Enola, PA 17025 Date of Notice: '~t//¢/~_~'> 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 NOTICE TO A LAWYER 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 W ELTMAN, WjE,~ B E RG.~. ~,/R~E ,S~ William T. I~l°lczan ' PA I.D. #47437 WELTMAN, WEINBERG'& REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #02583687 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. William-T.-~lolczan, Esq ~¢'e PA I.D. #47437 ,~' WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583687 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIRST SELECT, INC. Plaintiff VS. tENNIFER K. SCHMIDT Defendant No. 02-3562 C1VIL TERM ASSIGNMENT OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire Attorney for First Select, Inc. PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583687 IN THE COURT OF COMMON PLEAS OF CUMBERLAN D COUNTY, PENNSYLVANIA FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant No.02-3562 CIVIL TERM .ASSIGNMENT OF JUDGMENT KNOW ALL MEN BY THESE PRESENTS, that First Select, Inc, in consideration of the sum of $10.00 in hand paid to First Select, Inc, receipt of which is hereby acknowledged, and other good and valuable cons'deration, does hereby grant, bargain, transfer, assign and set over unto Credigy Receivables, Inc., whose address is Two Sun Court, Suite 450, Norcross, GA 30092, its successors and assigns, all of the fight, title, and interest of First Select, Inc, in and to that certain judgment entered by and in favor of First Select, Inc and docketed in the Court of Common Pleas of Cumberland County, in the Commonwealth of Pennsylvania, against Jennifer K. Schmidt, said judgment being in the amount of $5,534.62, in debt or damages, and the suni of costs of suit, together with all accrued interest, late charges, with all the benefit and advantages that may be obtained thereby, First Select, Inc does hereby grant to Credigy Receivables, Inc., its successors and assigns, full power to recover the same to its own use. This assignment is made without any recourse, warranty or representation whatsoever by First Select, lnc to Credigy Receivables, Inc. as to the judgment, its enforcement, and/or collectability. First Select, lnc does hereby further authorize and empower the Prothonotary or any attorney on behalf of the said Credigy Receivables, Inc. to mark the said judgment to its use. IN WITNESS WHEREOF, I have hereunto set my hand and seal this day of ,2003. WELTMAN, WEINBERG & REIS, CO., L.P.A. iam T. Molczan, J~quire Attorney for First Select, Inc. PA I.D. #4743?' WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583687 COMMONWEALTH OF PENNSYLVANIA ) ) COUNTY OF CUMBERLAND ) , On this, the _~ day o~ 2003, before me, a Notary Public in and for the aforesaid County and State, personally appeared William T. Molczan, Esquire, who acknowledged himself to be the attorney for First Select, Inc and being authorized to do so, executed the foregoing Assignment of Judgment for the purposes therein contained. Notary !/ubhc~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., SUCCESSOR 1N INTEREST TO FIRST SELECT, INC. Plaintiff VS. JENNIFER K. SCHMIDT Defendant No. 02-3562 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (PERSONAL PROPERTY EXECUTION ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. I.D.#47437 Gerianne Hannibal, Esquire PA 1.D.#66622 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02583687 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CREDIGY RECEIVABLES, INC., SUCCESSOR IN INTEREST TO FIRST SELECT, INC. Plaintiff vs. Civil Action No. 02-3562 CIVIL TERM JENNIFER K. SCHMIDT Detkndant PRAECIPE FOR WRIT OF EXECUTION {PERSONAL PROPERTY EXECUTION ONLY~ TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of Cumberland County: 2. against Jennifer K. Schrnidt, Defendant 3. Judgment Amount Interest at the rate of 6% per annum from 3/14/03 to 8/19/03 SUBTOTAL: Costs (to be added by Prothonotary): $5,534.62 $143.76 $5,678.38 $ WWR#02583687 WELTMAN, WE~NBER~A. B~iliam T.~Mo~zan~ t~uire PA. I.D.#47437 Gerianne Hannibal, Esquire PA I.D.#66622 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3562 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CREDIGY RECEIVABLES, INC., SUCCESSOR IN INTEREST TO FIRST SELECT, INC., Plaintiff (s) From JENNIFER K. SCHMIDT, 208 LOUIS LANE, ENOLA, PA 17025 (I) You are directed to levy upon the property of the defendant (s)and to sell PLEASE LEVY UPON ALL PERSONAL PROPERTY AT DEFENDANT'S ADDRESS OF 208 LOUIS LANE, ENOLA, PA 17025. (2) You are also directed to atlach the property of the defendant(s) not levied upon in the possession of GARxNISHEE(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 attachmant 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 $5,$34.62 L.L. $.50 Interest AT THE RATE OF 6% PER ANNUM FROM 3/14/03 TO 8/19/03 - $143.76 Atty's Corem % Due Prothy $I.00 Atty Paid $141.05 Other Costs Plaintiff Paid Date: AUGUST 25, 2003 (SeaD CURTIS IL LONG Prothonota~ REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, VOglNBERG & 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. 66622 Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3562 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CREDIGY RECEIVABLES, INC., SUCCESSOR IN INTEREST TO FIRST SELECT, INC., Plaintiff (s) From JENNIFER K. SCHMIDT, 208 LOUIS LANE, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell PLEASE LEVY UPON ALL PERSONAL PROPERTY AT DEFENDANT'S ADDRESS OF 208 LOUIS LANE, ENOLA, PA 17025. (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 $5,534.62 L.L. $.50 Interest AT THE RATE OF 6% PER ANNUM FROM 3/14/03 TO 8/19/03 - $143.76 Atty's Comm % Due Prothy $1.00 Arty Paid $141.05 Other Costs Plaintiff Paid Date: AUGUST 25, 2003 (Seal) Prothonota~ry Deputy CURTIS R. LONG REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE 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 1D No. 66622 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing 18.00 Poundage 1.41 Advertising Law Library .50 Prothonotary 1.00 Mileage 11.04 Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee TOTAL $ 71.95 Advance Costs: 150.00 SherifFs Costs: 71.95 $ 78.O5 Refunded to Atty on 10/21/03 Sworn and Subscribed to before me This ~.%d, day of 2003 A.D.Q~ ~. '~t~ ~' P~othonotary So Answ~s;~ ~,. R. Thomas Kline, Sheriff By Claudia A. Brewbaker FEDERMAN AND PHELAN, LLP By: Frank Fcderman, Esquire, Id. No. 12248 Lawrence T. Ph¢lan, Esquire, Id. No. 32227 Francis S. Hallinan, Esquire, Id. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 PNC Bank, NA VS. John D. Stone COURT OF COMMON PLEAS Cumberland COUNTY CIVIL ACTION No. 2002-3652 Civil ENTRY OF APPEARANCE To the Prothonotary: Kindly enter my appearance on behalf of Plaintiff, PNC Bank, NA, in the above captioned action. Date: '2JZ~ { o Sc FEDERMAN AND PHELAN, LLP By: /DCn~*~ '5]-M-°'~ FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire, Id. No. 12248 Lawrence T. Phelan, Esquire, Id. No. 32227 Francis S. Hallinan, Esquire, Id. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 PNC Bank, NA VS. John D. Stone COURT OF COMMON PLEAS Cumberland COUNTY C1VIL ACTION NO. 2002-3652 Civil CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Entry of Appearance was sent via first class mail, postage prepaid, to the following on the date indicated below: John D. Stone 272 South West Street Carlisle, PA 17013 Date: FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQU1RE