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HomeMy WebLinkAbout07-0253IN THE COITRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERA'I'EI) FINANCIAL Plaintiff vs. KIMBERLY HILL T'HEODORL PRODUCTIONS Defendants No. ~'?' - x.53 ~tc~~~, 1 ~~ COMPLAINT IN C'IV IL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF TI-IIS PARTY: James C. Warmbrodt, Esquire Pa I.D. No. 42524 Weltman, Weinberg & Reis, Co., LLC 2718 Koppers Building 436 Seventh Avenue Pittsburgh PA 15219 4I2-434-7955 WWII#05188148 IN TfIF COURT OF COMMON PLEAS CUMBERLAND COLII~TY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL Plaintiff vs. KIMBERLY HIC.L, THEODORE PRODUCTIONS Defendants 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 tiling 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. YOi 1 SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNO"T AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI-I BELOW TO FIND OUT WHERE YOU CAN GET LEGAL I-IEL,P LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD ST'REE1' CARLISLE, PA 17013 (717) 249-3166 ~,, '~ CASE NO: 2007-00253 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERATED FINANCIAL VS HILL KIMBERLY ET AL MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HILL KIMBERLY the DEFENDANT at 1608:00 HOURS, on the 25th day of January 2007 at 162 KEN LIN DRIVE CARLISLE, PA 17013 by handing to THEODORE HILL, HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.40 Affidavit .00 So Answers: Surcharge 10.00 R. Thomas Kline .00 32.40,/ 01/26/2007 WELTMAN WEINBERG REIS r""- 31-a 7 Sworn and Subscibed to By: before me this day Dep ty e f of A.D. SHERIFF'S RETURN - REGULAR `~ CASE NO: 200?-00253 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERATED FINANCIAL VS HILL KIMBERLY ET AL MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon THEODORE PRODUCTIONS the DEFENDANT at 1608:00 HOURS, on the 25th day of January 2007 at 162 KEN LIN DRIVE CARLISLE, PA 17013 by handing to THEODORE HILL, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service . 0 0 ~~1~,~~~ '~ Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00~/ 01/26/2007 WELTMAN WEINBERG REIS 1. ~~. b ~ - ~ Sworn and Subscibed to By: before me this day Deputy eri f of A.D. COMPLAINT 1. Plaintiff is a corporation with offices in 30955 NORTHWESTERN HWY, FARMINGTON HILLS, MI 48334-0000. 2. Defendant is an adult individual residing at 162 KEN LIN DR, CARLISLE,PA 17013. 3. Defendant is a corporation with offices in 162 KEN LIN DR, CARLISLE,PA 17013. 4. Defendants applied for and received a credit card issued by Plaintiff bearing the account number 5477533781740017. 5. Defendants made use of said credit card and has currently a balance due and owing to Plaintiff, as of December 6, 2006, in the amount of $22760.59. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1"and made a part hereof.. 6. Defendants are in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the en ire balance immediately due and payable. 7. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 31.53% per annum on the unpaid balance. 8. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendants, KIMBERLY HILL and THEODORE PRODUCTIONS, jointly and severally, in the amount of $22760.59 with continuing finance charges thereon. at the rate of 31.53% per annum from December 6, 2006 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. James C. rmbrodt, Esquire Pa LD. N 2524 Weltm , W inberg & Reis, Co., LLC 2718 K ppe s Building 436 Se en Avenue Pittsb rg PA 1.5219 412- 3 7955 :05188148 ADI//{NTA www.advanta.com Please check here if address, phone or e-mail changes are indicated on reverse side PAYMENT INFORMATION Account Number: 5477 5337 8174 0017 Payment Doe Date: NOW DUE New Balance: 14,698.14 Minimum Payment Due: 3,902.14 . , PLEASE WRITE IN ~ ~~ -. -. ._ • . PAYMENT ENCLOSED: i ., . THEODORE PRODUCTIONS 3404 MAKE PAYMENT TO: KIMBERLY HILL 162 KEN LIN DR ADVANTA BANK CORP CARLISLE PA 17013-9753 PO BOX 8088 RHILADELPHIA,PA 19101-8088 ~~~illtt~lllt~~tt~llttll~ltl„I~~~I,I~I~~~II~~II~~~~I~I~II~~ „,Iil~l~t~~~llll~t~~~~lllttl~ll~~~l~tltl~~l~l~~l~l~~l~l..I. 5477533781740D1? 1469814 0390214 ~ Detach Top Patton and F~close with Paymem ADI//1NTA ADVANTA EXECUTIVE BUSINESS CARD STATEMENT B X E C U CAR D ACCOUNT SUMMARY Account Number 5477 5337 8174 0017 Total Credit Limit 14,000.00 Total Credit Available 0.00 Cash Advance Credit Limit 14,000,00 Cash Advance Credit Available 0.00 Billing Cycle Closing Date 03/11/05 Days In Billing Cycle 30 Payment Due Date NOW DUE Minimum Payment Due 3,902.14 BALANCE SUMMARY Previous Balance 14,241.27 (+) Purchases & Cash Advances 0.00 (+) Miscellaneous Fees 78.00 (+) Finance Charge 378.87 (-) Payments 0.00 (-) Credits 0.00 (_) New Balance 14,498.14 TRANSACTIONS Trans Date Post Date Reference Number Activity Since Last Statement Amount 03/11 03/11 OVERLIMIT FEE 39.00 03/11 03/11 LATE FEE 39.00 *FINANCE CHARGE* PURCHASES $193.93 CASH ADVANCE $184.94 37g,87 IMPORTANT NEWS YOUR ACCOUNT IS CURRENTLY CLOSED YOUR CHARGE PRIVILEGES ARE TERMINATED! AVOID FURTHER DAMAGE TO YOUR CREDIT RATING. PLEASE D~F CALL US AT 1-866-271-7529. TOTAL *FINANCE CHARGE* BII,LED IN 2004 $3340.08 TOTAL *FINANCE CHARGE* PAID IN 2004 S 1832.46 FINANCE CHARGES PAYMENT SUMMARY Average Nominal Annual Daily Annual Finance Charges Payment Due 459 00 Daily Balance Percentage Rate Periodic Percentage Due to Daily Transaction . + Amount Over Credit Limit 698.14 Purchases 7,382.91 31.53% Rate .08756% Rate 31.53% Periodic Rates 193.93 Fees 0.00 + past Due Amount 2,745.00 =Minimum Payment Due 3 902 14 Cash Advances 7,040.65 31.53% .08756% 31.53% ]84.94 0.00 , . FOR CUSTOMER SERVICE, PLEASE CONTACT US: Online: ~ By Mall: Advanta Bank Corp. P.O. Box 30715, By Phone: www.advanta.com Salt Lake City, UT 84130-0715 ~ 1.800.705-7255 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION 5962 0002 X6D 1 7 7 050311 EX Page 1 of 1 8374 3700 P067 OlAA5962 3404 ~4D1//{NTA www.advanta.com Please check here if address, phone or e-mail changes are indicated on reverse side THEODORE PRODUCTIONS 221 KIMBERLY HILL 162 KEN LIN DR CARLISLE PA 17013-9753 ~t~lllt~tlll~tt~t~ll~~ll~l~l~~lt~~itl~l~t~ll~~ll~~t~l~l~ll~~ PAYMENT INFORMATION Account Number: 5477 5337 8174 OOl7 Payment Due Date: NOW DUE New Balance: 0.00 Minimum Payment Due: 0.00 • - •- . , PLEASE WRITE IN - -- -- ' •---°..---• •---.., . PAYMENT ENCLOSED: ~ . MAKE PA1 MENT TO: ADVANTA BANK CORP PO BOX 8088 PHILADELPHIA,PA 19101-8088 „~Ill~l~tt~~llll~~t~~~lllt~l,II.,~It~l~l~~ltl~~ltlt~l~l~~l~ 5477533781740017 0000000 0000000 • - Detach lop Portion and Enclose with Payment ADI//1NTA EXECUTIVE ADVANTA EXECUTIVE BUSINESS CARD STATEMENT B U S I N E S S C A R D ACCOUNT SUMMARY Account Number 5477 5337 8174 0017 Total Credit Limit 14,000.00 Total Credit Available 000 Cash Advance Credit Limit 14,000.00 Cash Advance Credit Available 0.00 Billing Cycle Closing Date 03/31/05 Days In Billing Cycle 30 Payment Due Date NOW DUE Minimum Payment Due 0.00 BALANCE SUMMARY Previous Balance 14,698.14 (+) Purchases & Cash Advances 0.00 (+) Miscellaneous Fees 0.00 (+) Finance Charge 0.00 (-) Payments 0.00 (-) Credits 11,640.55 (_) New Balance 000 TRANSACTIONS Trans Date Post Date Reference Number Activity Since Last Statement Amount 03/31 I 03/31 I F8374002U00999990 I CHARGE OFF ACCOUNT-PRINCIPALS I 03/31 03/31 F8374002U00999990 CHARGE OFF AC • COUNT FINANCE CHAR GES ^ - 1 ],640.55 - 3,057.59 IMPORTANT NEWS TOTAL "FINANCE CHARGE* BII,LED IN 2004 53340.08 TOTAL'FINANCE CHARGE• PAID IN 2004 51832.46 FINANCE CHARGES PAYMENT SUMMARY Average Nominal Annual Daily Annual Finance Charges Payment Due 0 00 Daily Balance Percentage Rate Periodic Percentage Due to Daily Transaction + Amount Over Credit Limit . 0 00 Purchases 0.00 31.53% Rate 08756% Rate 31 53% Periodic Rates 0 00 Fees + Past Due Amount . 0.00 Cash Advances 0.00 31.53% . .08756% . 31.53% . 0.00 0.00 0.00 =Minimum Payment Due 0.00 I FOR CUSTOMER SERVICE, PLEASE CONTACT US: Online: By Phone: - ~ By Mail: Advents Bank Corp. P.O. Box 30715, a ~ K'ww.advanta.com Salt Lake City, UT 84130-0715 ~ 1.800.705-7255 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION 5962 0001 X6D 1 3 7 050331 Z X Page 1 of 1 8374 3700 P067 OlAA6962 221 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that lte/she is JQa/~ ~/c°c°S (NAME) -- ~~~~ ~~'f cSdCS of ~u~~/~af~~ ~~~~_ ~ ', plaintiff herein, that Cs~~o. oi° .9~ r~~•c (TITLE) {COMPANY} heJshe is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best ofhis/her knowledge, information and belief.. (SIGNATURE) This Iaw firm is a debt collector attempting to collect this debt for our client and any information obtained will be used far that purpose. WWII#05188148 ~ ~ ~ f Y ~-~ ~- ~ a3 °=a ~ "' ` . ~. ~ ~ ,~- ~_. R_; ~' ~ ~ ~ ~~T ~p ~ ~ ~ 1",x,,"1 «...! ~... 0 ~'`~' ;~-r ~~ C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL Plaintiff vs. KIMBERLY HILL THEODORE PRODUCTIONS Defendants No. 07-253 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05188148 Judgment Amount $ 24538.14 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 FEDERATED FINANCIAL Plaintiff vs. KIMBERLY HILL THEODORE PRODUCTIONS Defendants TO THE PROTHONOTARY: Civil Action No. 07-253 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendants, KIMBERLY HILL THEODORE PRODUCTIONS above named, in the default of an Answer, in the amount of $24538.1.4 computed as follows: Amount claimed in Complaint $22760.59 Interest from DECEMBER 6, 2006 to APRIL 25, 2007 at the legal interest rate of 31.53% per annum $1777.55 TOTAL $24538.14 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. vV By: WILLIAM T. MOLCZ ,ESQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#05188148 Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7~' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendants is: 162 KEN LIN DR, CARLISLE,PA 170 Li IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL Plaintiff KIMBERLY HILL THEODORE PRODUCTIONS Defendants TO: Theodore Productions 162 Ken Lin Dr Carlisle,Pa 17013 Date of Notice: ~ - ~(-O~ IMPORTANT NOTICE 07-253 CIVIL TERM 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: ~ <~~~ James C. Warm dt, P.A.I.D.# 4252 Weltman,Wei e & Reis Co .,L.P.A. 436 Seventh ve ue, Suite 2718 Pittsburgh, PA I S 19 (412134-7955 Fax: 412-338-7 0 WWR #05188 48 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL Plaintiff KIMBERLY HILL THEODORE PRODUCTIONS Defendants TO: Kimberly Hill 162 Ken Lin Dr Carlisle,Pa 17013 Date of Notice: ~~-zC-~1') IMPORTANT NOTICE 07-253 CIVIL TERM 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. War b o P.A.I.D.# 4252 Weltman,Weinb r€ 436 Seventh Av n Pittsburgh, PA 1 2 (412)434-7955 Fax: 412-338 130 W WR #051 8148 & Reis Co .,L.P.A. ue, Suite 2718 19 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL Plaintiff vs KIMBERLY HILL THEODORE PRODUCTIONS Defendant Case no: 07-253 CIVIL TERM. NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, KIMBERLY HILL THEODORE PRODUCTIONS is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, KIMBERLY HILL THEODORE PRODUCTIONS is not in the military service. Further Affiant sayeth naught. / ,~' AFFIANT SWORN TO AND SUBSCRIBED in my presence this ~ day r+~ ~D~?. NOTARY PUBLIC r .~~ :,< w~ _ , t ~ , ~„ i e ~~ ~ ~ .. _~__ , ~ -- -~ ~-1 ~'ilij ~~ ti~ 'y . F >;;09 This law firm is a debt collector attempting to collect this debt for our c ' ~ any nfo~r~xiation ob ;ip~, ,~~1 be used for that purpose. ti1e~rber ~Zequest for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 APR-25-2007 08:05:28 -+C Last Name First/Middle Begin Date Active Duty Status Service/Agency THEODORE PRODUCTIONS Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. rte r~ ,~...y_a;~. Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq~is/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BYRWRRKJONP https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 4/25/2007 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 APR-25-2007 08:03:17 *K Last Name First/Middle Begin Date Active Duty Status Service/Agency HILL KIMBERLY Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. n~,~. ,w..~,-,ate Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. # 167;# 167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you aze strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Militazy Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: htt~//www.defenselink.mil/fad/pis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BZBCESHEFRZ https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 4/25/2007 ~ .~ r- i ~ -~ ~ ~ o - ~-~, ~ o~ ~~ -,, ~o ~ _ w ~- J :__ ~~; ~ o ~ ~. -~- ~: ~ ~ ~ ~~ ~ ~ ~~~ -~-- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL Plaintiff vs. KIMBERLY HILL THEODORE PRODUCTIONS Defendants KIMBERLY HILL THEODORE PRODUCTIONS 162 KEN LlN DR CARLISLE,PA 1.7013 Civil Action No. 07-253 C1:VIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on aUO~ (xx) Assumpsit Judgment in the amount of $24538.14 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROT NOTA Plaintiff s address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 I-888-434-0085 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-253 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FEDERATED FINANCIAL Plaintiff (s) From KIMBERLY HILL AND THEODORE PRODUCTIONS, 162 KEN LIN DRIVE, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ANY AND ALL OF DEFENDANTS PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: WOODFOREST NATIONAL BANK, 60 NOBLE BLVD., CARLISLE, PA 17013 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 $24,486.54 L.L. $.50 Interest $6,086.81 Atty's Comm % Due Prothy $2.00 Atty Paid $144.11 Other Costs: Plaintiff Paid Date: 7/26/11 Davi uell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 IN THE COUF:T OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL Plaintiff vs. KIMBERLY HILL THEODORE PRODUCTIONS 1 to a Y-& l %n 1Y. I &r-1? she I P I? 013 Defendant WOODFOREST NATIONAL BANK, (0o V?Y- ale I&Vcl,, (?,arlis?e 1 PIS t?ol3 Garnishee ?t?a(9a35s W f'61 & issued PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... l . directed w the Sheriff of CUMBERLAND County: 2. against KIMBERLY HILL AND THEODORE PRODUCTIONS, Defendant 3. againA WOODFOREST NATIONAL BANK, Garnishee 4. Judgment Amount $ Less payments of $ Interest $ Costs $ SUBTOTAL: $ Costs (tc be added by Prothonotary): $ S ?d a 41 t (.o. Do tt ! ! S IS, 50 tt !' Y.po1k!( a.so tt?! >r y CP1,01 a H? 7) ?.? Civil Action No. 07-253 CIVIL TERIV)rn . era r- ??; r ;Q BCD y c7 M ?- , CD " C, = - CD C 24538.14 51.60 6086.81 30573.35 WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 SDGL WWR#05188148 c,? IoU18???O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FEDERATED FINANCIAL Plaintiff vs. KIMBERLY HILL THEODORE PRODUCTIONS Defendant WOODFOREST NATIONAL BANK, Garnishee, No. 07-253 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT and LEVY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05188148 POPM 1 1 ?.D-.D FFiCE C'Plaw • e-1 • 2-63 D 11 A GP,?, ?r\NRUAGP'L'VS• ?t INTERROGATORIES IN ATTAC MBERLAND COUNTY PENN5YLY move or l , At the tine you were served or at any subsequent time did you owe the e t any Y were you liable to him on any negotiable or th funds?on deposit for tche king or savings accoun se ndi ertifiic tes of or were liable to him for my reason (including deposit)? NO KCC?-t reof; I a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount ocation of money you owe or owed to defendant, oand, if we such money is in the fo of a tten wed to defendant on ea h of suchtnegopresent tiable for othertweri the terms, face amount and amount you instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. ON- 2. At she time you were sed or at any any property of any nature owned solely ors in custodbyythe control of yourself and one or more other persons defendant. NN 3, At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? Na 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? NN 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or plane pursuant to your directions or consent and if so what was the consideration thereof? t46 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? NPR 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 111 K 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, (lid not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. N.V. 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. N 01c 10. If the. answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. Nj?r 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not deposited e'ectronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? NN 12. If the response to Interrogatory I 1 is in the affirmative, state the amount of non-exempt funds on deposit in the account. Wv WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05188148 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is,.k:r=Ea\C-_ (Name) {' '?f4?Y V\C ?D ?( of )ps ?FbQS=ST ?cC?ot.?}?_, garnishee herein, (Title) $PcN IL (Company) that he/she is duly wathorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. WZtk;?=', Woodforest Natlonal Bank-Legal Dept. Bryan Abraham Jessica Black 82-375-2898 -phone fax Cedrick Frazier 832"375-3071 _ 25231 Grogan's Mill Rd, Suite 100 The Woodlands, TX 77380 81,\1 WELTMVJ, WEINBERG & REIS CO., L.P.A. BY: James C WArmbrodt, Esquire Attorney for Plaintiff(s) I.D. No.42524 436 Seventh A-,.=e, Suite 1400 Pittsburgh, )'A l.')'219 Phu-tie: 412.434.1955 Fax: 412.434.79--,9 C File # 5188348 - cnm G rn r <)> FEDERATED FINANCIAL r-x - Cumberland County ?? a ra-n Court of Common Pleas 26 - O VS. KIMBERL' HILL THEODORE PRODUCTIONS NO. 07-253 CIVIL TERM and WOODFOREST NATIONAL BANK Garr ishee(s) P1RAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO i'HE PROTI-tONOTARY: Kindly aiarl...-d the above matter discontinued and ended as to Garnishee(s), WOODFOREST NATIONAL. BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By James nWarmbrodt, Esquire Atto v for Plaintiff Sworn to and s,?scribed Before me :he 1,_ day of August, 2011 NOTARY P1iBLiC 48.0o P0 A`rri/ ?-? l F PENNSYLVANIA i 0-* /00$$03 { COMMONWEA H s Watvan NOWY Pub'! ? a ? 3 858 Sheila G. BBVBN, County ? Ross TwQ-, N1e9heny 2014 Commissbn FxPi?' Nov. 15, My ARIES TION OF NOT MEMBER, PENNSYLVANIA ASSA SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff rot ,,,r,t,r ILEO-OFFJCcr. Jody S Smith oTNL' PP,0THOr4,9 T;^, Chief Deputy 2011 SEP 12 PM 2: ( Richard W Stewart Solicitor CQU14TY PENNSYLVANIA Federated Financial Corporation vs. Kimberly Hill (et al.) Case Number 2007-253 SHERIFF'S RETURN OF SERVICE 08101/2011 10:18 AM - Tim Black, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Woodforest National Bank at 60 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to TRACIE KONDEK, BRANCH MANAGER, personally two three true and attested copies of the Writ of Execution and made the contents there of known to her. SO ANSWERS, ? September 09, 2011 RON R ANDERSON, SHERIFF Ti y Black, Deputy RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy To Whom It May Concern: o0tp of ?urrr?Pr?? a OFFICE OF THE SHERIFF One Courthouse Square, Room 303 RICHARD W. STEWART Solicitor Carlisle, Pennsylvania 17013 r-a m C/5 ? September 30 2011 rn r?- ran ?- --°? , -E> O p Federated Financial r- "`=?' -v --t r7 -"? vs ==G °j? Kimberly Hill & Theodore Productions w Writ No. 2007-253 Property Claim Determination Reference is made to Property Claim dated September 20, 2011, entered by Theodore Hill, Writ of Execution No. 2007-253 Civil Term, Federated Financial vs. Kimberly Hill and Theodore Productions. Ronny R. Anderson, Sheriff, has determined that the claimant, Theodore Hill, in the above mentioned property claim, is the owner of the property set forth in the claim. So B cc Matthew Urban, Atty for Plaintiff Kimberly Hill & Theodore Productions, Defendant Theodore Hill, Claimant Anderson, S eriff 0-14' 0 , NOTICE OF PROPERTY CLAIM Federated Financial In the Court of Common Pleas Cumberland County, Pennsylvania VS Kimberly Hill & No. 2007-253 Civil Term Theodore Productions Writ of Execution TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Theodore Hill, claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 09-20-11 riff of Cumberland County Cc Matthew D. Urban, Atty for Plaintiff Kimberly Hill & Theodore Productions, Defendant Theodore Hill, Claimant PROPERTY CLAIM ??. d e?cc? ed 'Etna Y?c ?'O)e IL --M uA4 VS ?"006 TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA 10-P5 In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. / The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE W W't j C( Ct 0 THE CLABIANT 04TAINEWITLE TO TM PROPERTY AS Date ;?o APPe I I I Claimant State sylvania: County of Cumberland 7-?Z- 12?'a above list in the property claim are correct and true. Swoa? su f ore mg _ L rThisb? 1c R, NOTARY PUBUC Carlisle Boro, Cumberland County My Commission Expires April4, 2018 713?e being duly sworn according to law, deposes and says that the Claimant WMW- 61\kA?ha'5 4' 10. (1) 3 a,(A-1I?,on 3D, co . V i bc) -- N '5 - J - '6 ?k'' (001(i V?PI-614 W?,?1a. ??r ?cr? lv?feQ?-ate - (??PPec? e??t?:? 1 Cdr {? ro ?, ? j?-? ?toJe.. -aver l? .? r5 0l 1 ? 4k?6 ( 15.E (-s o 4rCd\ k mp adD(- - eae.r t? I r5 a?A -4pP N?m& - oJeX t5 *--D 011 a? rt? - (? UoWe? 4z?, 5+M?? W"?{?,? ?o den h???1 a ??c 4 ac)oL -okt- \V3 o kr ,ebu?e5 P?cQc?- ?ab<<12t Roctunq ?(cALL c&4 ?cQr C?mp? M4r50U vc,b,LL a o -5 tb, oo o0 C), CO 5bf o0 3(D. m ?U,m 6-,bb 15-bb S.Co 5.00 law @S 00 5-b-OD X0.00 a5-00 g? 500 DICD 66,w ?.C, 1?.w 3otao 5.00 his; ct p2pe?ic{ U)aSkf . -- o&c' 15yC5 6` 1 d??? aver ?5y? alc? &zv-?wt - a 4v? ???VLQI? -?-?4C, n. . 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OD 35-, n) SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Anderson L k L-.r. t ,ff , 4{ ?it?utfr a J ,dy S Smith ?+ rtr,?d I Pik a!jt ; C ?M 5'14 E. .thief Deputy ?012MAR22 AMIO, 44 Richard W Stewart Solicitor "CUMBERLAND C0UjgT `r` PENNSYLVANIA Federated Financial Corporation Case Number vs. 2007-253 Kimberly Hill (et al.) SHERIFF'S RETURN OF SERVICE 08/01/2011 10:18 AM - Tim Black, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Woodforest National Bank at 60 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to TRACIE K©NDEK, BRANCH MANAGER, personally two three true and attested copies of the Writ of Execution and made the contents there of known to her. 09/08/2011 04:35 PM - Gerald Worthington, Deputy, being duly sworn according to law, states that on September 08, 2011 at 4:35 PM hours, served the requested Writ of Execution and Claim for Exemption Form by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, tc wit: Kimberly Hill at 162 Ken Lin Drive, Monroe Township, Carlisle, PA 17013, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on September 9, 2011. 09/08/2011 04:35 PM - Deputy Gerald Worthington, being duly sworn according to law, served the requested Writ of Execution and Claim for Exemption Form to a person representing themselves to be Theodore Productions - CEO/President/ Husband, who accepted as "Adult Person in Charge" for the within named Defendant, to wit: Theodore Productions at 162 Ken Lin Drive, Monroe Township, Carlisle, PA 17013, informed person of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on September 9, 2011. 09/20/2011 On 09/20/11, at 1219 hours, a property claim was filed by Theodore L. Hill. All parties notified by mail this date. 03/21/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $161.82 March 21, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF a . ov vo ;SOitCr SN!nlf_ Teleosoft. Inc.