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HomeMy WebLinkAbout02-3805NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF Vo TODD M McCABE, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ~p. 3~(9.5"' ~ 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 IMPORTANT RIGHTS. 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. Date: August 1, 2002 Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 Ste~~ BY: .~ 9 Bridge Street j"' New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF TODD M. McCABE DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. COMPLAINT 1. New Cumberland Federal Credit Union is a federally chartered non-profit credit union with its principal place of business being 345 Lewisberry Road, New Cumberland, Pennsylvania 17070. 2. Defendant Todd M. McCabe is an adult individual residing at 211 Louis Lane, Enola, Cumberland County, Pennsylvania 17025-2142. Count I: Breach of Contract on Loan 3. On or about June 7, 1999 Defendant executed a Promissory Note and Disclosure Statement as "borrower" in favor of the Plaintiff in the amount of Twenty Four Thousand Two Hundred Nine and 66/100 Dollars ($24,209.66) at 11.00% interest. A tree and correct copy of the foregoing document is attached hereto as Exhibit "A". 4. Defendant pledged as security for this loan a 1996 Dodge RAM 1500 pick up truck which was repossessed due to non-payment o£the monthly installments and sold at auction leaving a balance of $8,700.96 with a per diem of $2.55 from July 17, 2002 to present. 5. Defendant's monthly payment under the Promissory Note was $558.26 per month or $128.83 weekly. 6. As of July 17, 2002 the past due interest was $244.45 accruing at $2.55 per day. 7. Under the terms of the Promissory Note Defendant must repay the Plaintiff its reasonable attorneys fees and all costs of collection. 8. Defendant has failed to cure the default. WHEREFORE, Plaimiff respectfully requests this court to enter judgment in its favor and against Defendant Todd M. McCabe in the amount $8,700.96 plus all costs of collection, court costs, reasonable attorneys' fees and 11.00% interest calculated at $2.55 per day from July 17, 2002. Count H: Breach of Contract on Loan 9. On or about July 12, 2001 Defendant executed a Promissory Note and Disclosure Statement as "borrower" in favor of the Plaintiff in the amount of Eight Thousand Seven Hundred Ninety Four and 38/100 Dollars ($8,794.38) at 12.90% imerest. A true and correct copy of the foregoing document is attached hereto as Exhibit "B". 10. Defendant's monthly paymem under the Promissory Note was $308.53 per month or $70.23 weekly. 11. As of July 17, 2002 the past due interest was $158.71 accruing at $2.27 per day. 12. Under the terms of the Promissory Note Defendant must repay the Plaintiff its reasonable attorneys fees and all costs of collection. 13. Defendant has failed to cure the default. 2 WltEREFORE, Plaintiff respectfully requests this court to enter judgment in its favor and against Defendant Todd M. McCabe in the amount $6,570.82 plus all costs of collection, court costs, reasonable attorneys' fees and 12.90% interest calculated at $2.27 per day from July 17, 2002. BY: J 619 Bridge Street // New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. I am authorized as the President of the New Cumberland Federal Credit Union to execute this document on behalf of the corporation. BY: Donald M. Varner~esident New Cumberland Federal Credit Union, A non-profit federally chartered credit union Date: Note an' r r EW CUMBERLAND FEDERAL CREDIT UNION Disclosure Statement New Cumberland, PA 17070-0658 (717) 774-4633 · 1-800-716-2328 BORROWER NAME (Leal - First - MiUdle InBJal) AND ADDRESS (Streel - City - State - Zip Code) DATE MEMBER NUMBER NOTE NUMBER TODD PI NCCAEI/ PO BOX 701 JUNE 7. 1999 076142 L 2 NEW' CUH Ef ER LA N O P A 17070 ~ONTRACT NUMBER REFERENCE NUMBER - MATURITY DAI'E Late Charge: Filing Fees Non-~ TH[$ CREDZT UNZON DOES NOT ASSESS LATE CHARGES $ ~FORMATION ABOUT NONPAYMENT $ N/A ITEMIZATION OF THE AMOUNT FINANCED DEFAULT AND ANy REQUIRED REPAYMENT IN FULL BEFORE THE SCHEDULED DATE. ITEMIZATJON OF AMOUNT GIVER AMOUNT PAiD ON AMOUNTFINANCEDOF$ _24,209.66 TOYOUDIRECTLy$ 23.450°70 YOURACCOUNT $ PREPAID FINANCE AMOUNTPAIDTOOTHERS $ ~ 0 o O0 CHARGE sN/A ON YOUR BEHAL~ $ O. 0 0 TO $ ~ _$ o.oo To Collec'UonCosts: You promise to pav all costs ,-n o~.fi ~ m~ ................ ~_..~ ..... operyearuntiiwha you owe has been repaJd . o ..ll~..n~ ,.. '"',,','~'H, yVU VWU u.u~r m~ agreemen Ir~ttJolng court costs and reasonab e attorney tees, ~ MODEL _ YEAR LD. NUMBER · : TYPE VALUE ~;'17. 675. O0 ot,.,,n,..,.,: wO:' C · teral't 8y doing so a ree . y u are not a borrower but an owner AUTION. ITIBIMPORTANTTHATYOUTHORO NL¥1aIFan~-~ you g only to the terms of the Secud A of t#e collaterel for t~/s /oarc UG .......... $ CONTRACT BEFORE YOU SIGN IT. ty £rearnont. , .... ate Borrower 2 r'l (3whir nf r. ..... ~,~. y~wper OT u_om_~[e raj (other than a Borrower) D Credit insuranes ia voluntary and not m'qulred in O~er to eMain this loan YOU may s~lect DO'NOT SIGN THIS APPLICATION iF iT CONTAINS ANY 8LANK SPACES. any meurer of your choice. You are applying to the Society for credit insurance on your This appllcallon is void and wttl not be used In a conlest I all blank spaces have not loan, You agree to pay the premium charges shown. The rate for this coverage is sudject been oompleteg, if he member has not slgne,~ and daled the Apptteatton, and if the to change, You will be notified in advance ~efore a rate increase is nut nfo effect ~,'.,~ ~ ~ .,~ .~crea~ ~ - AllplicaBon has not been wltllesaed. TODD H NCCABE eo,eow~ ~ JUNE 26~, 1563 076142 'UNDER CREDIT LIFE AND DISABILITY THE MAXIMUM EL GIBILITY.~AGE FOR COVERAGE IS 65, WITH NO MAXIMUM TERMINATION AGE. ~ THE FOLLOWING STATEMENTS MAeE SY YOU/UTE REPRESENTATIONS AND ARE TRUE TO THE BEST OF YOUR KNOWLEDGE AND BELIEF: MAXIMUM AMOUNT OR LOAN INSURABLE MAXIMUM MONTHLY TOTAL DISABJMTY $ NONE begin with the ~bleG for more than day of disabirit¥. NOTE (Continued) /ou gve in your she es and dopes s; A properly other td; n th/igllng: th~' ,.~t, ~, LAtE CHARGE -- If VOU are late in making a paymer t, you agree [opay t~e late connec[on with this loan. You will be n detault if you d e, ' e J )~, . ~ , , ~,, ~, ,'Jif OLI I%i, L: hS 'i:jhtS. ' ' ¢,mll 38 .n defauR if you make any talse SECURITY AGREEMENT ' ' security interest in the property described ib the "Securit~ Offered!' se~: c , H:e Ir / L do not i[ay tile taxes or fees on the property when due or keep it insured, the E U If the pr,~dg nkm adds al~0td[a lot [axes, !ecs, or instraece to your loan ewe ~ne credit union for any reason now or in the future, ex¢cpl any tear s, L ~: ~: WtI,kT HAPPENS IF YOU ARE IN DEFAULT -- When you a~e ii default, the Cl'edH the aroger~y is itousehold goods as de ned by the Credit Practice Role; ]he ]~nF~,t, ~ u~,t oq the Join ant take possess~oH Of the p'opbrte You at roe ~ e e edit Onion has OWNERSHIP OF THE PROPERTY -- You promise that you owrl ti;,, p'au ti, !% t,Jan iS tO buy the proderty, },'OLJ promise yOU will ese the Ioalr 1 )1 h'a[ nil?! E PROTECTING THE SECURITY INTEREST -- if yoer state issues a tith l,:,a t~,, ? ~ t(Ivance i(di;;e If you are asked lo do so by tile credJt un;on you promise ~,~ ~oticeof uypubricsaleorPlede~eefterwhicn p vaesa,;,¥ be ed. Tht · n;neiqg statement You also promise to do ,vhatever el~e the erebil unolr Ilir14 i: ~' q it[ed lin(Irt stere law or atverded under §506(b of the 8ankrJptcy Cbde. Th( ecessary~¢pr~tectilssecuntym[erestin[heproper[y!, i i~ , ~ 's ¢I the sal~, o]oaey will be appiied to w~a: you owe on the lnar~ USE OF PROP~EFiTY ~ Until the loan has been,paid off,'-yd~J?~'rbniis~ ~,o~'~1 ' Use ; :PT ~,,a~ have agwed tc pay he can, you will aisc have o pay a y amount that remain ~ properly carefully and keep it in good'repair;'(2) Oblain!¢ritten permisefc,'n'lmm ~',Snpair~ after the sale money has b~ea a~plied lo what you owe on tire loan acc .ode; credit union before making major changes to tile properly i(3) Inforn] l!~e credit 'pitt: ~ gree~ en You agree to pay ~n e es on ha amc nt at ~he came tale as the in ,arl n wrding Pelore cl]anglng your address or the address where Iht pr ,;n!? is inhl that anlount has been pate, ~,ept (4) Atlow the credit union to inspect tile property. (5) Promptly noti~ tr:~ t ri dit ,~mon ,f the property is damaged, stol;n or abused. (6) Not use t~e propert, far PROPERTY INSURANCE, TAXES AND FEES -- You promise to pay al to×es L]ELA¥ IN ENFORJ;ItlG RIGHTS AND CIIANOES IN TilE AGREEMENT -- 'The credi FOR TENNESSEE CREDIT UNIONs ONLY -- " USE WHEN AUTOMOBILE IS PURCHASED NOTICE: If you do not purchase Ihe insurance required on the automobile aid t e nedlt oat!, n~e credrt unioh'S intelest in die properS, The insulance will not de liGbJiily in tJt~ I 8 YOU have read the above statement an(, ackl:owledge ldat the crud un o r Aus e iliaiqdd THE PROPERTY DESCRIPTION Oil THE REVERSE SIDE IS PART OF THIS AGREEMENT. , NOTICE: SIGN THIS AGREEMEI,1T ON',THE REVERSE SINE. , / i :red~t Umon Aparoval X FOR NORTH DAKOTA CREDIT UNIONS ONLY ~- APPLIES ONLY WHEN A MOTOR VEHICLE IS PURCHASED 'lrll~E THE ~OFOR VEHICLE IN THIS YRANSACrlON M,,/Y I~E SU[~/ECT T :~:FOaSESSION iP II IS REPOSStSSED AND SOI.D ]O SOMEONE ELSE, AND AL : hlOLNI'S DUE FO TH~ SECURED PARTY ARE NOT RECEIVED IN tHAT SAL~, ~0 IdAY nAVE fO ;:AY THE BIFFEREf'JCE Note and Disclosure Statement I'~cw L.L/IViUh-.~LA~-iU t'~'~t-I-~AL IJHEDII' UNIOA ROi BOX 658 ' New Cumberland, PA 17070-0658 (717) 774-4633 * 1-800-716-2328 TODD H HCCABE JUL~Y 211 LOUIS LN C0NTRACTNuMB[R REFEREN-N~'~MBER---. M~bATE ENOLA PA 17025-2142 ~and anyone to whom Number of Pa men~ $ , ........ Pro e In . Schedule ~ 5 5 rmm a~o~ y~u ~nt ~al ~ a~pab~ m ~e ~r~-~:~ 7 [. 2 0 · e good~prope~ ~--~ Other (D~ -' You are giving a ~curi~ interest in your s~r~ an~or de~si~ Jn the credit union; and ~ Late C~roe; being pumh~ed; Filing Fees ' ~n.Fil~e TH[S CREDZT UN[ON DOES NOT ASSESS LATE CHARGES $ ~ON~ ~NFORMATION ABOUT NONPA ........ $ N ~~~,R~ REPAYMENT ,N FULL 8E~,~ T~' '- . TO YOU DIRECTLY$ 3 S [ ~. 7 8 YOUR ACCOUNT $ PREPAIO FiaNCE ~0U~PAID/00THERS $ 0. 00 To ' Pmmi~ ~ Pay: You promi~ to pay $ ~ ~ - 8,7 9 4.3 ~ the credit union plus nterest on ~e unpaid balance at[ 2.9 0 0 % per ~ar until whet you owe has ~en re,ab CoRe,on Come: ~ p~i~ ~ p~ ag ~ of ~lj~ ~ a~unt ~ ~ u~er this agr~ment including ~u~ ~sts ~ re~on~le aEomey ~e' ~ MODEL Y~R ~U~ TYPE VALUE 0tber (Describe): ~pos~tsof$ 0.00 in account number 076142 KeyNo Thi .[~L~ON: n'is IM~YA~ THAT YOU ..... [t.e. Ml . 8y doing so you agree only to the terms of the ~ D...... .;, l_f__y_ou_ are not a borrower but an owner of the collat Credit insurmlCe is VD uota~ a~l not required In re'der to oMain ~-'-' ~. :; .e : DO NOT SIGN THIS APPLICATION I any insurer of your choice. You ar, A,,n~,,;.~ ,~., - . i!gan, YOU may smect F IT CONTAINS ANY BLANK CFR I°an' Y°U agree to paY the n~ml~ -["~-~':~-~-'~-'.e,~°cJeb~ f°-r credit tflsuranc~ on yOU r This app cation is void and WIg not be u SPA TODD M MCCASE · *UNDER !ii~ ~, , :~ ]j ~,.~ F~,t ;i,;',~,:~:~ ? ~ . CREDIT LIFE AND DISABIU'TY'THE MAXIMUM ELJGISJ.UTY~GE FOR cOVERAGE IS 65, wITH NO MAXIMUM TERMINATION AGE, ~ THE FOil. OWING STATEMENT~ MARE BY YOU ARE REPRESENTATION$ AND ARE I' ' CR~ .... ~,m~ ~CatN~AT RUE TO THE BEST DF XOUR I(NOWLEpGE AND 8EUEF: -- CREDIT DISABILITY INSURANCE '~-- MIOM SCHEgU[E YEA l NO COVERAGE ~ELECl~O ' MAXJMUM AMouKr OF LONd iNSURAR LE[ IS ~__ --' ~ MAXIMUM M~OUNT OF LOAN INSURABLE g~kRJ~J DiSABiLITY BENEFIT I , E eD.nO __ l_ _ '"r'LO' ABI.TYBS.EFIT e ~ D^TE~ ' $ 75 ,~ ooo /~O,~.C~IC~OR~eRi ~'~ ~ ,egin with the. ,at da~ ,~f ......... Y, ,the d,sab,h~ benefit PAY ~ENTS -- You pramme to nrake pa;,menls of the amount and at toe time shown VVhee YOU are in default, the credit u~icn cad demauP immediate payment ef Ihe . .e.~.~ Y)u may mare ~arger Daeme ~ w.th~. * ..- ?. ~?1 what you owe has ~een unpaid balance of [hs Iota wi out ~v ~ g you advanc~ ' 9, :..'.e subsem~en payn e~t~ wi ~e~'~',~.~. ?na~tT. fl~ou eD prepay ~a~ ct what demands immediate Darn ant ~ ~ ~ ~ ~ , . ~ohce. If me c[emt u~ on ..... scueoueoor vou ...... ~ doric ~ake a~lhesalneinteresl~al~untfl~v~u~.an?.youvzm.llconli~uelopayinlerest ~ ~ ' ~ ou~ of he ob]er payn ents You n n ~ - y be demanded immediate payment of ~-:~ oeen ?paid. If tbn DroOl union has ~,2ce c']( sen by the Credit union ~ %' '~ ~o i]]aK~ ~a~menls at the .~u ua anco, t~ credd union can apply LOANS BY MAIL -- If this ]cae ~hat you owe. The credit un on can also exe F .. *~,, ;, ' t~,~ a~n.em~]t CWmds ?'ur,d~Yarrthes]a~esanddenos s ~'/*.- ~-°~,y~uagree~tds~°anisaso n;d~vdualtyo adansl~ ..... U e other loans w,,, thc c, eP,t u,aon w,I, also secure Ibis ,oau hines Wit,o,t los,no ,,s~li~;on can ,olay entorc,ng any ct ,ts r,gNs any ,umber DEFAULT ~ You wig be n dehult it you do not make aoplicat oq or undo. ~ ?Y false or misleadieg S"ate,nents in an- ~ ~ ?u a? m default on a heanc al oblinahon fe.~:~a,~~cnl~L ~.CUIT UNIONS -- SECURITY AGREEMENT , - ......... ~ . _ _ ~ _ _ ~. terences to "the can" mean the can de.~.~-., ..... ??). ssigns the can All pro~ of .r:n~ ,- ~ cy p~yab~e 10 lhe c e umon ~]nd to d h ~ ~ECURITY FOR THE LOAN g si ~' ' . '; refund [ e ~ron=~,,i~ i. .... edit unon has a ri h s'gnature area or by sign ,g Ih, ,tateme~ r~--~- ??-s~curny agreemen n h~ ' se, e~ent to r;-a~;::~= .~.,.u, uamag~d the cred union can ~Se the ~,~ tb~ ...... ~.~ lo [ms agreement on the back'0f c ed t u~ on fo ~-~i~ prQp~.dr apply ,t towards who you owe You ..,~2~T ....... any ora. or ch~ck which may b~ payable ~o ~ ,,:,'? ,,te/es~ in ~he property descr bed io lhe "Secur~ .... ,~wn asa the credd Ur o to coUect ,.- p~ :.~..,,~ h] e esl yOU give ncudes all accessions An~"~r? sec o~ The If ou do n ~ ~ u.u ur uene ~ts dale 'n Er yOU: tsurance crc c: :n~ ex:ensions. ~enewa s or rebna}]~Zr~-'~'~ ~,~..y~u uu~ w~thi~ ~0 days ct the loan ~q~....,.~o~. spa{IDs for loxes, tees o~ msu a mc wil~ rt'e ~/.~' ~n~ money the ?u rece,ve f om sel,'i, ..... one-. % ......... oa~. it aisc includes any, mooey .. ~n'~'u wm pa~ ~nterest on ~n,se amoun s at l* e sam~ r ~;"~: '~ ,ou~ ~oan ,he va~ue of the pronen~ ~';~1~-~' ~',~.~r ircm ,nsu{ance you ~ave on the pror, en. Il . , . t the credlL un*on adds amou~ ts or taza. f.-- y' u ag,eud [o pay un as securgv i¢ asked"to ~ s~ y.. promrse to g,ye the credit union nlbre'~Op;~ty ' ' ~,anc~, ~?~ payments may be ncrease~ by'~'n ~, ~r. msu,'an~e lo you, ~oan WHAT THE SECURITy iNTEREST COVERS-- T~ e DEFAULT ~ You w~ll be in defau t ~ ,,o r eaL any ~, rnise you aCe u~d~ tips ).,[ r pr,~clpaJ res once e -r ...... ~¢ copt any loan sec ed b LOANUNER~ Nolo. . ~.~.,y u~.u~p,mon ,s harked wm ] cue star (. ~ o~ WHAT HAPPENS IF YOU ARE IN DEFAULT -- When ~)LJ are mn Petamdh the credit OWNERSHIP OF THE PROPERTY -- You pmm~se th Ihe igbtto ~ake DSS ' Uec ~ t unin~:/.~:~e~roy rot ~ loan w t' and ~er credo until ,,-.:;,~'.~;.~. 'l~at you leare inside he pro~er~ The~'~ ~ ~2y' ~] covered bt ~IPs agreemen P~OTECTING THE SECURITY NTERE~T I Our s ' money receive~ o aa amount The creed un;on may have to I;~:~'~ uu?~ se?rity ieteresl s own 6n he e ,,,r ~x~en~,.3uy P~OUC sale or the da~e after wh ch a n-'zat~,':.:'~v'Lu? ~ve me proFe'ty carelutty and keep in ~o,,~ .~'.~,,~.~,,~o~ promise you will:(1 Use If you ~ave anree~ *~ --,:*~ , "" ed .. ~ha~ ycu owe ou ~he loaf] ..... ~"". tz; uo[mn wrnten permission from unp;' ~..~ ~,,~a~, yo~ wrl, E also bave to p ~, any anluunl that i , ams Id a,er th .......... , .... eon a,~p,,ed ,o what yin; owe co tie Ica,, t~e crec~t union before n akglg n ajor changes to; he proper~z ~3) nform the creed this ~greemeN. You agree to pay m~erest on hat amc r t]t - kepL 4, AllOW the credi u~ on o insnect th ........ ~ a~.r~ss where the prope~y is until that amouot has beeo paid t ~e same ra,e as ~u Joao PROPERT~INSURANCE T~ES AND FEES -- You ton ' . : g . e nsa~,'~zme any ndmDer o[ nos (~kereg~straPontees) dueoa he-m-ed ...... P ~rse lo pay al taxes and fees w~t~ootlosmgth~abd]~ 0exercsensn,~l ~t~r T ~cedtuno can en o ce this able, lhe Other terms will remain in effect THE PROPERTY DESCRIPTION ON THE REVERSE SlOE IS P~RT OF THIS AGREEMENT, - NOTICE: SION THIS AGREEMENT ON THE REVERSE SLOE. Credit lJnio~ Approval X NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF V. TODD M. McCABE DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 3805 CIVIL TO: Defendant Todd M. McCabe 211 Louis Lane Enola, PA 17025 DATE OF NOTICE: September 12, 2002 IMPORTANT NOTICE 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 (10) 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 AVISO IMPORTANTE FECHA DEL AVISO: September 12, 2002 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUIRIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO IMMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENE LIN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 BY: S~n Hox~efl, F~quirre J619 Bridge Street J New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney For Plaintiff Certificate of Service I hereby certify that on the date set forth below a tree and correct copy of the foregoing document was served upon all counsel of record via postage prepaid, first class United States Mail addressed as follows: Todd M. McCabe 211 Louis Lane Enola, PA 17025 Date: September 12, 2002 SHERIFF'S CASE NO: 2002-03805 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NEW CUMBERLAND FEDERAL CREDIT VS MCCABE TODD RETURN - REGULAR SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT & NOTICE was served upon MCCABE TODD M the law, DEFENDANT at 1843:00 HOURS, on the 19th day of August at 211 LOUIS LANE , 2002 ENOLA, PA 17025-2142 NIKKIA MCCABE, DAUGHTER a true and attested copy of by handing to COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this 2~/~ day of ~,, ~,~ ~-/30 2.~ A.D. tWrc~chonot ~ry ' ~ So Answers: R. Thomas Kline 08/20/2002 STEVEN HOWELL_ -- By: - ~ ./ VDep%fty Sheriff NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF VS. TODD M. McCABE, DEFENDANT 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 3805 CIVIL TERM PRAECIPE TO ENTER DEFAULT JUDGMENT AGAINST DEFENDANT TO THE PROTHONOTARY: Please enter a default judgment in the mount of $15,271.78 plus court costs, interest and reasonable counsel fees as of September 26, 2002 against the Defendant due to his failure to respond to the Complaint served upon him on August 19, 2002. A 10 Day Notice was served on September 12, 2002 as shown on the attached Certificates of Mailing and filed on September 13, 2002. No answer having been filed or served as of September 25, 2002 please enter the default judgment. ~ ~verv~0x(ell, Esquire J 6~2 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff Date: September 25, 2002 Certificate of Service I hereby certify that on the date set forth below a true and correct copy of the foregoing document was served upon all interested parties or counsel of record via postage prepaid, first class United States Mail addressed as follows: Todd M. McCabe 211 Louis Lane Enola, PA 17025 Date: September 25, 2002 By: even Howell,~mre NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF V. TODD M. McCABE DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02- 3805 CIVIL TO: Defendant Todd M. McCabe 211 Louis Lane Enola, PA 17025 DATE OF NOTICE: September 12, 2002 IMPORTANT NOTICE 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 (10) 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 AVISOIMPORTANTE FECHA DEL AVISO: September 12, 2002 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION IUEQUIRIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO IMMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENE UN ABOGAD0 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA 0FICINA ABA JO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ridge Street umberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney For Plaintiff Certificate of Service I hereby certify that on the date set forth below a tree and correct copy of the foregoing document was served upon ail counsel of record via postage prepaid, first class United States Mail addressed as follows: Todd M. McCabe 211 Louis Lane Enola, PA 17025 Date: September 12, 2002 BY: Stev/m/H°~veli' l~s~// u.s. POSTAL SERVICE CERTIFICATE OF MAILING MAY SE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT Received F $[even Howell A~orney A[ L~w 619 Bridge Street New CmnbeAand, PA 17070 "rot;r2 WI e ¢ PS Form 3817, Janua~ 2001 NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF TODD M. McCABE, DEFENDANT TO: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 02 - 3805 CIVIL ENTRY OF DEFAULT JUDGMENT AGAINST DEFENDANT Defendant Todd M. McCabe 211 Louis Lane Enola, PA 17025 YOU ARE HEREBy NOTIFIED THAT ON SEPTEMBER 26, 2002 THE FOLLOWING JUDGMENT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE CAPTIONED CASE. For Cotmt I: Judgment in the amount of Eight Thousand Seven Hundred and 96/100 ($8,700.96); plus court costs; interest of $181.05 (71 days) calculated at 11.00% interest or $2.55 per day from July 17, 2002; and reasonable attorneys' fees. Four Count II: Judgment in the amount of Six Thousand Five Hundred Seventy and 82/100 (6,570.82); plus court costs; interest of $161.17 (71 days) calculated at 11.00% interest or $2.27 per day from July 17, 2002; and reasonable attorneys' fees. Prothonotary Certification of Defendant's Address I HEREBy CERTIFY THAT THE NAME AND ADDRESS OF THE PROPER PERSONS TO RECEIVE THIS NOTICE IS: Todd M. McCabe 211 Louis Lane Enola, PA 17025 Date: September 25, 2002 By: ulre New Cumberland, PA17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff IN THE COURT OF ~ PLEAS OF ~ COUNTY, ~VANIA C~LD~SI~ NEW CUMBERLAND FEDERAL CREDIT : File No. 02 - 3805 UNION, : Amount Due $15,271.78 PLAINTIFF : Interest $ 274.74 VS. : Atty's Con%m $ 300.00 TODD M. McCABE, : Costs DEFENDANT (57 Days $4.82 Per Diem from 9/25/02] TO THE PROTHONOTARY OFT HE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of jud~aent, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as araended; and for real property pursuant to Act 6 of 1974 as ~mended. PRA~CIPE FOR EXECUTION Issue writ of execution in the above matter to the Sheriff ~umberland County, for debt, interest and costs upon the following described property of the defendant(s) Defendant's bank account at Community Banks~ 201 St. John's ~ha~ch Road, Camp Hill, PA 17011 PRAECIPE FOR A~A~ EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named galmishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Garnishee Community Banks, 201 St. Johns Chnrch Road, Camp Hill, PA 17011 and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a ~ pendens against real estate of the defendant(s) described in the attached DATE: I / /9! /0 ~- Signature: Print N~. Steven Howell, Esquire Ad~s.- 61 9 Bridge Street New Cumberland, PA 17070 Attorney for: Plaintiff Telephone: ( 717 ) 770 - 1277 Suprerae Court ID No.: 62063 Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3805 Civil COUNTY OF CUMBERLAND) CIVIL ACTION LAW TO THE SHERiFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NEW CUMBERLAND FEDERAL CREDIT UNION Plaintiff (s) From TODD M. MCCABE, 211 LOUIS LANE, ENOLA PA 17025. (1) You are directed to levy upon the property of the defendant (s)and to sell ~ (2) Y°u are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMUNITY BANK, 201 ST. JOHNS CHURCH RD., CAMP HILL PA 17011. GARNISHEE(S) as follows: SERVE INTERROGATORIES AND ATTACH DEFT'S BANK ACCOUNT AT GARNISHEE E BANK-. 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 pr°perty °f 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 $15,271.78 Interest 57 DAYS ~ $4.82/DIEM FROM 9/25/02 Atty's Comm $300.00% Atty Paid $115.85 Plaintiff Paid Date: November 27, 2002 (Seal) REQUESTING PARTY: Name STEVEN HOWELL, ESQ Address: 619 BRIDGE ST. NEW CUMBERLAND PA 17070 Attorney for: PLAINTIFF Telephone: (717) 770-1277 Supreme Court ID No. 62063 L.L. $.50 $274.74 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary By:(~ ~,.L 7Z-J~ ~~ ~/epu{y ~_~ SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-03805 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND NEW CUMBERLAND FEDERAL CREDIT VS MCCABE TODD And now RICHARD SMITH ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:03 Hours, on the 12th day of December , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , MCCABE TODD M , in the hands, possession, or control of the within named Garnishee COMMUNITY BANK 201 ST JOHNS ROAD CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to PAULETTE ROVITO (MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /~ day of ~,.,,¢.~ ~ 2~ ~ A. D. Pr~ot/honot ary So answe_rs -~ ~ ~ R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo By NEW CUMBERLAND FEDERAL CREDIT UNION V. TODD M. McCABE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-3805 CIVIL TERM ORDER OF COURT AND NOW, January 13, 2003, Todd M. McCabe having been notified that a hearing on his Claim for Exemption was set for 1:30 p.m. this date in Courtroom No. 3, and the defendant having failed to appear to testify on his claim, the claim is dismissed. By the Court, Steven Howell, Esquire 619 Bridge Street New Cumberland, PA 17070 For the Plaintiff Todd M. McCabe 211 Louis Lane Enola, PA 17025 NEW CUMBERLAND FEDERAL CREDIT UNION, Plaintiff Vo TODD M. M~CABE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-3805 CIVIL TERM CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 27th day of January, 2003, by agreementi of the parties, the Plaintiff is directed to return $300.00 cash to the Defendant which represents his one-time statutory exemption. The remaining claim for exemption as to the prope!rty at issue is withdrawn. By the Court, Edward E. Guido, J. ~even HOwell, Esquire Attorney for Plaintiff /_odd M. McCabe 211 Louis Lane Enola, PA 17025 Defendant, Pro se srs V~VA!,~SNNi]d ,kLNfluO ..... , ......... WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3805 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NEW CUMBERLAND FEDERAL CREDIT UNION Plaintiff (s) From TODD M. MCCABE, 211 LOUIS LANE, ENOLA PA 17025. (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMUNITY BANK, 201 ST. JOHNS CHURCH RD., CAMP HILL PA 17011. GARNISHEE(S) as follows: SERVE INTERROGATORIES AND ATTACH DEFT'S BANK ACCOUNT AT GARNISHEE E BANK-. 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 t'fim/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $15,271.78 Interest 57 DAYS ~ $4.82/DIEM FROM 9/25/02 Atty's Comm $300.00% Atty Paid $115.85 Plaintiff Paid Date: November 27, 2002 (Seal) REQUESTING PARTY: Name STEVEN HOWELL, ESQ Address: 619 BRIDGE ST. NEW CUMBERLAND PA 17070 Attorney for: PLAINTIFF Telephone: (717) 770-1277 Supreme Court ID No. 62063 L.L. $.50 $274.74 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothc~otary BY:d ~t'-~ff~/e~ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. SherifFs Costs: Docketing 18.00 Poundage 10.00 Advertising Law Library .50 Prothonotary 1.00 Mileage 9.66 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee 9.00 TOTAL $ 88.16 Sworn and Subscribed to before me Advance Costs: 150.00 Sheriff's Costs: 88.16 $ 61.84 Refunded to Atty on 4/28/03 P~. Thomas Klin_e-, Sheriff t~y LAallola/-X. t~rewoaKer - IN THE O003~T OF CC~9~DN PLEAS OF C~ COUNTY, ~VANIA NEW CUMBERLAND FEDERAL CREDIT UNION, PLAINTIFF VS. TODD M. McCABE, DEFENDANT CIVIL DMSION : File No. : Amount Due : Interest : Atty's Co~n Costs 02 - 3805 XX~XXXXXX~ $14,809.52 $ 274.74 (57 Days at $ 600.00 $4,82 Per Diem ~,~,02 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of jud~nent, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRA~CIPE FOR EXECUTION Issue writ of execution in the above matter to the Sheriff of Cumberland COunty, for debt, interest and costs upon the following described ~roperty of the defendant(s) All personal property located at:211 Louis Lane Enola, Cumberland County Penns~ania 1~~ PRA~CIPE FOR ATT~ ~3c~J_3TION Issue writ of attacP~ent to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-n~ned garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ~ (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendanT(s) described in the attached exhibit. April 28 2003 ~~ DATE: ' - Signature: __ Print~ Steven Howell, Esquire Address: 619 Bridge Street New Cumberland, PA 17070 Attorney for: Plain'tiff Telephone: (717) 770-1277 Supreme Court ID No.: 62063 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3805 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NEW CUMBERLAND FEDERAL CREDIT UNION, Plaintiff (s) From TODD M. MCCABE, 211 LOUIS LANE, ENOLA, CUMBERLANDCOUNTY, PENNSYLVANIA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY LOCATED AT 211 LOUIS LANE, ENOLA, CUMBERLAND COUNTY, 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 gamishee(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 $14,809.52 L.L. $.50 Interest $274.74 (57 DAYS AT $4.82 PER DIEM FROM 9/25/02) Atty's Comm % $600.00 Due Prothy $1.00 Atty Paid $216.01 Other Costs Plaintiff Paid Date: APRIL 29, 2003 (Seal) REQUESTING PARTY: Name STEVEN HOWELL, ESQUIRE Address: 619 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 71%770-1277 CURTIS R. LONG Prothonotary Deputy Supreme Court ID No. 62063 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3805 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NEW CUMBERLAND FEDERAL CREDIT UNION Plaintiff (s) From TODD M. MCCABE, 211 LOUIS LANE, ENOLA PA 17025. (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMUNITY BANK, 201 ST. JOHNS CHURCH RD., CAMP HILL PA 17011. GARNISHEE(S) as follows: SERVE INTERROGATORIES AND ATTACH DEFT'S BANK ACCOUNT AT GARNISHEE E BANK-. 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 $15,271.78 L.L. $.50 Interest 57 DAYS ~ $4.82/DIEM FROM 9/25/02 $274.74 Atty's Comm $300.00% Atty Paid $115.85 Plaintiff Paid Date: November 27, 2002 (Seal) REQUESTING PARTY: Name STEVEN HOWELL, ESQ Address: 619 BRIDGE ST. NEW CUMBERLAND PA 17070 Attorney for: PLAINTIFF Telephone: (717) 770-1277 Supreme Court ID No. 62063 Due Prothy $1.00 Other Costs CURTIS R. LONG Proth~tary BY:~ ~L '~]j/e~ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 18.00 Poundage 10.00 Advertising Law Library .50 Prothonotary 1.00 Mileage 9.66 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee 9.00 TOTAL $ 88.16 Sworn and Subscribed to before me Advance Costs: 150.00 Sheriff's Costs: 88.16 $ 61.84 Refunded to Atty on 4/28/03 Thomas Klinr,, Sheriff By Claudia A. BrewlSaker WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3805 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NEW CUMBERLAND FEDERAL CREDIT UNION, Plaintiff (s) From TODD M. MCCABE, 211 LOUIS LANE, ENOLA, CUMBERLANDCOUNTY, PENNSYLVANIA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY LOCATED AT 211 LOUIS LANE, ENOLA, CUMBERLAND COUNTY, 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 $14,809.52 L.L. $.50 Interest $274.74 (57 DAYS AT $4.82 PER DIEM FROM 9/25/02) Due Prothy $1.00 Atty's Comm % $600.00 Atty Paid $216.01 Plaintiff Paid Date: APRIL 29, 2003 (Seal) Other Costs CURTIS R. LONG Deputy REQUESTING PARTY: Name STEVEN HOWELL, ESQUIRE Address: 619 BRIDGE STREET NEW CUMBERLAND, PA 17070 Attorney for: PLAINTIFF Telephone: 717-770-1277 Supreme Court ID No. 62063 R. Thomas Kline, Sheriff, who being duly swom according to law, states this writ is returned STAYED, DUE TO BANKRUPTCY. Sheriff's Costs: Docketing $ 18.00 Poundage 1.01 Advertising Law Library .50 Prothonotary 1.00 Mileage 11.04 Misc. Surcharge 20.00 Levy Post Pone Sale Garnishee TOTAL 51.55 Sworn and Subscribed to before me this/d. ~ day of 2003 A.D. (,~,,_. Pro~h(~notary Advance Costs: 150.00 Sheriff's Costs: 51.55 98.45 Refunded to Atty on 5/14/03 So An~sv~ers:.~ R. Thomas Kline, Sheriff By (~: