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HomeMy WebLinkAbout07-0745 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 07-745 Civil Term Plaintiff, TYPE OF PLEADING: VS. Praecipe for Default Judgment DONNA J. BOLDOSSER, TYPE OF CASE: Defendant. Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff's Address: 2700 Sanders Road COUNSEL OF RECORD: ` Prospect Heights, IL 60070 CATHY ANN CHROMULAK, ESQUIRE PA ID NO. 42067 Defendant's Address: MAUREEN A. DOWD, ESQUIRE 28 FAIRFIELD STREET PA ID NO. 90549 NEWVILLE, PA 17241 KURT J. WINTER, ESQUIRE PAID NO. 84801 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Dated: MARCH 13, 2007 Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 46 46 TO: PROTHONOTARY Please enter judgment by default against the within-named defendant, DONNA J. BOLDOSSER, for failure to file an Answer as follows: Amount Claimed in Complaint: $71752.09 Interest from 12/12/06 through 3/13/07: 350.97 Costs of Collection through 3/13/07: 503.06 TOTAL $89606.12 With interest accruing on the total balance of $8,606.12 at the rate of 6% per annum, together with additional costs of suit. BY CATHY AZ1N CHROMULAK, ESQUIRE MAUREEN A. DOWD, ESQUIRE KURT J. WINTER, ESQUIRE Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATION OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF WASHINGTON ) Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared, V iF f Aj A. Q W , ESQUIRE, attorney for and authorized representative of plaintiff who, being duly sworn according to law, deposes and says that the defendant is not in the military service of the United States of America to the best of her/his knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed to defendant on MARCH 1, 2007 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attached copy. ddA&!??s ZZA.L., A.... ?Q? CAT ANN CHROMULAK, ESQUIRE MAUREEN A. DOWD, ESQUIRE KURT J. WINTER, ESQUIRE Sworn to and subscribed before me This day of M4 d_61 , 2007. 4 1 &i;Kv ?, OL Notary Public .?OMMONWEALTH OF PENNSYLV'ANlr? ' Notarial Seal Heather L Hatfield, Notary Public Cecil Twp., Washington County MY Commission Expires June 29, 2010 ""F,, nber, Ponnaylvnnia k3sociatk)n of Notar e. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Vs. Plaintiff, DONNA J. BOLDOSSER, Defendant(s). TO: DONNA J. BOLDOSSER 28 FAIRFIELD STREET NEWVILLE, PA 17241 DATE OF NOTICE: MARCH 1, 2007 CIVIL DIVISION No. 07-745 CIVIL TERM 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 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. By: CATHY AN& CHROMULAK, ESQ. MAUREEN A. DOWD, ESQ. KURT J. WINTER, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4`h Floor Canonsburg, PA 15317 i ?? V ' V' o g c c g- m ? 6 G C6 m a ro m $ o C$C o ifi 7J 3 t? p CL -i in ??.?. W act Ci o Q w u w.g w n a. *tn w do ?I& 3 (a OD co m r N w ? q w r v ??y z ? 0 o a '? c-o LA 97? ?oCi ?? 7d r- ITI -z C) 1.11 V) 0 -4 ?. ?tA of r > to a d C h ? ro o a Y 00 v r ? N ? a .h .o ? 9 W 0. ooc?o? m 0 3 CA a? W m pt ? m7m jq G G ' r„i,1, `i,'C9 {a,V CID, may r;'.°J 1t?a,.1 0?? W V c -Ta t V? q rn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 07-745 Civil Term Plaintiff, VS. DONNA J. BOLDOSSER, Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: DONNA J. BOLDOSSER 28 FAIRFIELD STREET NEWVILLE, PA 17241 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on () A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $8,606.12 plus interest at the rate of 6% per annum and additional costs of suit. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. 07 -'7qs DONNA J. BOLDOSSER Defendant(s) 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 OR 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. o,7- 7yi? Plaintiff, VS. DONNA J. BOLDOSSER, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 28 FAIRFIELD STREET NEWVILLE, PA 17241 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 KURT J. WINTER, ESQ. PA ID NO. 84801 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 4`h Floor Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 4 7- .7 q'5- Cu t.! 7-'e4- Plaintiff, VS. DONNA J. BOLDOSSER, Defendant. COMPLAINT AND NOW COMES, the Plaintiff, BENEFICIAL CONSUMER DISCOUNT COMPANY, by its Attorneys, Chromulak & Associates, LLC, with its Civil Action Complaint, the following of which is a statement thereof: 1. BENEFICIAL CONSUMER DISCOUNT COMPANY is a Corporation, duly authorized to conduct business in the Commonwealth of Pennsylvania, with its principal office situated at 2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred to as "Plaintiff'. 2. DONNA J. BOLDOSSER is an adult individual residing at 28 FAIRFIELD STREET, NEWVILLE, PA 17241. 3. On or about APRIL 11, 2005, Defendant entered into a written Loan Agreement with the Plaintiff, a copy of which is attached hereto as "Exhibit A" and incorporated herein. 4. Pursuant to the Loan Agreement with Defendant, Plaintiff advanced funds to the Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5. Defendant is in default under the terms and conditions of the aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about AUGUST 10, 2005. 6. Pursuant to the terms of the Loan Agreement, Plaintiff has the right to require payment of the entire amount owed upon default. The total amount due, including principal and interest, and owing by the Defendant is in the sum of SEVEN THOUSAND SEVEN HUNDRED FIFTY TWO AND 9/100 ($7,752.09) DOLLARS as of DECEMBER 11, 2006. 7. Numerous demands have been made upon Defendant by Plaintiff, but Defendant has failed or refused to pay. 8. Pursuant to the Loan Agreement, Plaintiff is entitled to recover costs of collection and reasonable attorney's fees. WHEREFORE, Plaintiff claims damages in the sum of SEVEN THOUSAND SEVEN HUNDRED FIFTY TWO AND 9/100 ($7,752.09) DOLLARS, with interest thereon at the rate of 18.45% from DECEMBER 11, 2006, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC By: CAT Y ANN CHROMULAK, ESQ. PA ID 0.42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 KURT J. WINTER, ESQ. PA ID NO. 84801 Attorneys for Plaintiff 375 Southpointe Boulevard THIS IS AN ATTEMPT TO 4th Floor COLLECT A DEBT AND ANY Canonsburg, PA 15317 INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. LOAN REPAYMENT AND SECURITY AGREEMENT (Page 1 of 3) LENDER (called "We", "Us", "Our") BENEFICIAL CONSUMER DISCOUNT COMPANY 418 STONEHEDGE DRIVE SUITE 2 CARLISLE PA 11013 BORROWERS (called "You", "Your") BOLDOSSER, DONNA J 28 FAIRFIELD ST NEWVILLE PA 11241 LOAN NO: 111115-662181 REQUIRED INSURANCE. You must obtain insurance for term of loan covering security for this loan as indicated below, naming us as Loss Payee: Title insurance on real estate security. Fire and extended coverage insurance on real estate security. Physical damage insurance on vehicle listed under "Security" above if "Y" appears under "Insured". Physical damage insurance on other property listed under "Security" above if "Y" appears under "Insured". You may obtain any required insurance from anyone you choose. (See "Security" paragraph above for description of security to be insured.) 05-01-04 NRE II?II????11111?? EXHIBIT 1111ujIM11l11 PAB75021 it A aB56F6342BK99CEA9000PA675021 1 ORIGINAL LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3) PAYMENT. In return for this loan, you will pay us the Total of Payments (the sum of Finance Charges plus Amount Financed), in monthly payments stated on page one. The Finance Charge is the total of Interest plus Service Charge. You may pay more at any time. You will pay us at our business address as stated on page one or other address given you. If more than one Borrower is named on page one, we may enforce this Agreement against all, or any, Borrowers, but not in a combined amount greater than the amount owed. DATE ON WHICH FINANCE CHARGE BEGINS. Finance Charges begin on the date of disbursement. If this loan is made by mail, the date on which the Finance Charge begins is postponed by the number of days from the date of this Agreement to the date of disbursement. Payment due dates and effective date of any optional insurance purchased are also postponed. PAYOUTS. You agree to payouts of Amount Financed as shown on Truth-In-Lending disclosure form. If payouts change because loan closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check will be reduced to cover additional payouts. PREPAYMENT. If you fully pay before final payment due date, the amount you owe will be reduced by unearned Finance Charge (but not Service Charge) determined by the "Rule of 78ths". MATURITY. After the final payment due date stated on page one you will pay interest at the rate of 18% per year. SECURITY. You agree to give us a security interest in the property identified on page one, which will secure all indebtedness, including future advances under this Agreement. LATE CHARGE. If you don't pay any payment in 10 days after it's due, you will also pay 1 112% per month on the amount overdue (subject to a $1.00 minimum charge). BAD CHECK CHARGE. We will charge you a fee of $20 if any payment check is returned because of insufficient funds or is otherwise dishonored. You agree that we may deduct this charge from a monthly payment. FAILURE TO PAY. If you don't pay any payment on time or fail to keep any required insurance in force, (a) all your payments may become due at once and without notifying you before bringing suit, we may sue for the total amount you owe less any unearned Finance Charges you would receive if you fully prepaid, and (b) you will also pay our reasonable attorney fees, if the attorney is not our salaried employee, for legal proceedings to collect this loan or realize on security. EXCHANGE OF INFORMATION. You understand that from time to time we may receive credit information concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a regular basis, we obtain related to your Account, including but not limited to credit reports and insurance information, with any of our affiliated corporations, subsidiaries or other third parties. The uses of this information may include an inquiry to determine if you qualify for additional offers of credit. You also authorize us to share any information regarding your Account with any of our affiliated corporations, subsidiaries or other third parties. You may prohibit the sharing of such information (except for the sharing of information about transactions or experiences between us and you) by sending a written request which contains your full name, Social Security Number and Address to us at P.O. Box 1547, Chesapeake, VA 23320. If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent of such department) may release your residence address to us, should it become necessary to locate you. You agree that our supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the quality of our service to you. INSURANCE. Optional credit insurance and any required insurance disclosures are attached to this Agreement and are incorporated herein by reference. ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDERS. The terms of the Arbitration Agreement and any other Riders signed as part of this loan transaction are incorporated into this Agreement by reference. APPLICABLE LAW. The Pennsylvania Consumer Discount Company Act (CDCA), Title 7, Purdon's Pennsylvania Statutes, governs this loan. NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS. 05-01-04 NRE PAB75022 !INSIiiINI I IN??NCINVl III11? IogoNI11NN11 Rill 1111111111IIN "B56F6342BK99CEA9000PA8750220""aOLDOSSER it ORIGINAL LOAN REPAYMENT AND SECURITY AGREEMENT (Page 3 of 3) YOU HAVE RECEIVED A COMPLETE COPY OF THIS AGREEMENT AND THE TRUTH-IN-LENDING DISCLOSURES. 05-01-04 NRE PA575023 NSSSF6342SK99CEA9000PAB750230x"BOLDOSSER " ORIGINAL BORROWERS: La J S3'"(SEAL) TRUTH-IN-LENDING DISCLOSURES (Page 1 of 2) LENDER (Called "We", "Our", "Us") BENEFICIAL CONSUMER DISCOUNT COMPANY 419 STONEHEDGE DRIVE SUITE 2 CARLISLE PA 17013 BORROWERS (Called "You", "Your") BOLDOSSER, DONNA J 28 FAIRFIELD ST NEWVILLE PA 17241 LOAN NO: 711715-562187 • ANNUAL • FINANCE Amount Total of Payment Date of Financed The amount you will PERCENTAGE CHARGE The amount of credi have paid after you Loan RATE The dollar amount provided to you or o have made all pay- The cost of your credit credit will cost the your behalf. menu as scheduled. you, as a yearly rate. 27.293% 1 $ ?..... -vmwnt schedule will 931 s 5951.99 $ 9841.92 { 04/11105 1 047 mount $ 205.04 05/11105 $ 205.04 l Day 11 of each month thereafter. Late Charge: If you don't pay any payment in 10 days after it's due, you will also pay 1 112% per month on the amount overdue (subject to a $1.00 minimum charge). Prepayment: If you pay off early, you may be entitled to a refund of part of the Finance Charge. See the contract documents for any additional information about nonpayment, default, any required repayment in full before the scheduled date, and prepayment refunds. NOTICE: The following page(s) contain(s) additional information. 08-14-04 NRE TIL II'' PAS 18121 IIII?l?I?I1W??I?IIIIIINI?u?Wi11II?II???IWI1111???UAI?Il111?1????'??U? KB58F6342BK99FE09000PA8161210a"BOL00SSER a ORIGINAL TRUTH-IN-LENDING DISCLOSURES (Page 2 of 2) ITEMIZATION OF THE AMOUNT FINANCED CREDIT LIFE INSURANCE (PAID TO INSURANCE COMPANY) .............................s 114.50 CREDIT DISABILITY INSURANCE (PAID TO INSURANCE COMPANY) .......................s 389.14 CREDIT INVOLUNTARY UNEMPLOYMENT INSURANCE (PAID TO INSURANCE COMPANY) ......... s 387.11 CASH OR CHECK TO BORROWER.......,.,.. .........................•••s 4999.98 Loan Fee........... .......................s 150.00 PREPAID FINANCE CHARGES (TOTAL) ...............................................s 150.00 AMOUNT FINANCED (EXCLUDING PREPAID FINANCE CHARGE) ......... .... ............... s 5951.99 08-14-04 NRE TIL PAB18122 I?f?I?IMfuIIIIIIII?IN?IN???I?I???a?NfII?II??IinVIIIIIV????If? *BSBF63420K99FE09000PABI8122ONN80LDOSSER * ORIGINAL VERIFICATION DIANNA WI G G I N S , Recover Specialist for BENEFICIAL CONSUMER DISCO Deposes and says subject to the penalties of 18 Pa C.S. Section 4904 relating to unworn falsification to authorities, that the facts set forth in the forgoing Complaint are true and correct to the best of her knowledge, information and belief. i t DIANNA WIGGINS l a e-? L? C.? G 0 ,I 6 f'1 l -C) 0 . 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION vs. DONNA J. BOLDOSSER and Defendant, FARMERS NATIONAL BANK Garnishee, and ADAMS COUNTY NATIONAL BANK Garnishee, and F&M TRUST Garnishee. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 28 FAIRFIELD STREET NEWVILLE, PA 17241 No. 07-745 CIVIL TERM TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 CHRISTINE A. SAUNDERS, ESQ. PA ID NO. 203373 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 Date: April 30, 2007 f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY Plaintiff, No. 07-745 CIVIL TERM VS. DONNA J. BOLDOSSER Defendant, and FARMERS NATIONAL BANK Garnishee, and ADAMS COUNTY NATIONAL BANK Garnishee, And F&M TRUST TO: The Prothonotary Garnishee. PRAECIPE FOR WRIT OF EXECUTION Please issue a Writ of Execution in the above matter, 1. directed to the Sheriff of CUMBERLAND County; 2. against DONNA J. BOLDOSSER, defendant, and 3. against FARMERS NATIONAL BANK, garnishee, and 4. against ADAMS COUNTY NATIONAL BANK, garnishee, and 5. against F&M TRUST, garnishee, 6. and index this writ a. against DONNA J. BOLDOSSER, defendant, and against FARMERS NATIONAL BANK, garnishee, and any property of the defendant in the name of Garnishee, and -'-c. against ADAMS COUNTY NATIONAL BANK, garnishee, and any property of \4-,r the defendant in the name of Garnishee, and \d. against F&M TRUST, garnishee and any property of the defendant in the name of Garnishee: Famm I?vmd 6m k 37 ChAL- e W Oeuvi lle , PA 1'7a 4 t Ac{0.na Coun4,1 OQ?60ra bt I Wesi Bic3 Sprirn Ave Oewv i tie , PA l Aq I F+ m `rr r>+ Soy E . Hi h S+ CUxgisle, 117or3 Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual and joint, personal and business. 7. Amount of Judgment Additional Interest to Date (Costs to be added) $8,606.12 $ 87.23 Pursuant to Writ of Execution And Service of Writ THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. $8,693.35 E-2pit-Q? -. CATHY ANN CHROMULAK, ESQ. MAUREEN A. DOWD, ESQ. CHRISTINE A. SAUNDERS, ESQ. BETH ARNOLD HOWELL, ESQ. 4L b VAt 9-5 c ? r-? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-745 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From DONNA J. BOLDOSSER, 28 FAIRFIELD STREET, NEWVILLE, PA 17241 (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 FARMERS NATIONAL BANK, 37 CARLISLE RD., NEWVILLE, PA 17241 -- ADAMS COUNTY NATIONAL BANK, 1 WEST BIG SPRING AVE., NEWVILLE, PA 17241 -- F&M TRUST, 800 E. HIGH ST., CARLISLE, PA 17013 - GARNISH ANY PROPERTY OF THE DEFENDANT IN THE NAME OF THE GARNISHEES 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 $8,606.12 Interest $87.23 Atty's Comm % Arty Paid $135.06 Plaintiff Paid Date: MAY 30, 2007 (Seal) REQUESTING PARTY: Name BETH ARNOLD HOWELL, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 L.L. $.50 Due Prothy $2.00 Other Costs iieputy Supreme Court ID No. 203606 SHERIFF'S RETURN - REGULAR CASE NO: 2007-00745 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS BOLDOSSER DONNA J WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE the BOLDOSSER DONNA J was served upon DEFENDANT at 1402:00 HOURS, on the 9th day of February 2007 at 28 FAIRFIELD STREET NEWVILLE, PA 17241 by handing to DONNA BOLDOSSER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscibed to before me this day of , 18.00 10.56 .00 10.00 .00 38.56? So Answers: R. Thomas Kline 02/12/2007 CHROMULAK & ASSOCIATES By: Deput eriff A. D. all -% do ?& IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Beneficial Consumer Discount Company, Plaintiff, V. Donna J. Boldosser, Defendant, and Farmers National Bank, Garnishee, and Adams County National Bank, Garnishee, and F&M Trust, Garnishee. Judgment & Writ Number 07-745 CIVIL TERM Attachment Execution Proceedings PROOF OF NOTICE TO DEFENDANT COMMONWEALTH OF PENNSYLVANIA, COUNTY OF ADAMS. On this, the a 776 day of June, 2007, before me, a Notary Public, in and for said Commonwealth and County, the undersigned officer, personally appeared Edward G. Puhl, Esquire, attorney for Adams County National Bank, the Garnishee in the above entitled attachment execution proceedings, who having been by me duly sworn, according to law, on his oath, does depose and say that on June 27, 2007, he forwarded to the Defendant, Donna J. Boldosser, a copy of the writ issued in said proceedings on June 13, 2007, and a copy of the answer to Interrogatories Adams County National Bank, Garnishee, by mailing the same certified mail deposited at the post office in Gettysburg, Adams County, Pennsylvania, addressed to the Defendant at the following address: 28 Fairfield Street, Newville, Pennsylvania 17241. Attached to this Proof of Notice is the certified mail receipt showing the aforesaid mailing of the items hereinbefore mentioned. Edward G. Puhl, Esquire Sworn to and subscribed before me this d 7"1* day of June, 2007. Notary Public My commission expires: COMMONNMYN OF PENNMVANU? - - -- Nodal Seal t"1b R. sdmea. Notary Puft My coffi sim Ey" occ 2s, in" Ptaaayk" w? CM - Er Ln -I- I tT Postage $ co _D Certified Fee 7 Return Receipt Fee (Endorsement Required) O Restricted Delivery Fee C3 (Endorsement Required) O O M Total Postage & Fees Is 3 , c?3 / ark R tpient s Name (Please Print Clearly) (to be completed by mailer) o!ln4- S $o1do?Sef ----------------------------------------- Stree Apt. No.; or PO Box No. Fai?fiebl_ 3*f City, State, ZIP+4 7.2 tT 1j 0 M1 ?ci C? . ? ? ? °'" ??s c ,.. ?{-; ,-a7 ?? .rw? .?, R " _. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV. CIVIL ACTION - LAW Beneficial Consumer Discount Company, No. 07-745 CIVIL TERM Plaintiff, vs. Donna J. Boldosser, and Farmers National Bank, and Adams County National Bank, and F&M Trust, Defendant, Garnishee, Garnishee, Garnishee. CERTIFICATE OF SERVICE AND NOW, this j7f? day of June, 2007, I, Edward G. Puhl, Esquire, of Puhl, Eastman & Thrasher, attorney for Garnishee, Adams County National Bank, hereby certify that I have this date served Garnishee's Answers to Interrogatories, by mailing the original and one true copy first class mail, postage prepaid, to Beth Arnold Howell, Esquire, at the address shown below: 375 Southpointe Boulevard 4' Floor Canonsburg, PA 15317 PURL, EASTMAN & THRASHER By: Edward G. Puhl, Esquire Attorney ID# 55709 Attorney for Garnishee 220 Baltimore Street Gettysburg, PA 17325 (717) 334-2159 N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY vs. DONNA J. BOLDOSSER 28 FAIRFIELD STREET NEWVILLE, PA 17241 and FARMERS NATIONAL BANK Plaintiff, Defendant, Garnishee, and ADAMS COUNTY NATIONAL BANK Garnishee, And F&M TRUST Garnishee. TO: ADAMS COUNTY NATIONAL BANK 1 WEST BIG SPRING AVE. NEWVILLE, PA 17241 n -C C7 cv CD c? 4 © You are required to file Answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. u.LrS. INTERROGATORIES TO GARNISHEE FIRST: At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him/her on any negotiable or other written instrument, or did he/she claim that you owed him/her any money or that you were liable to him/her for any reason: RESPONSE: Y l SECOND: If your response to the previous interrogatory was anything other than an unqualified negative, set forth the amount of the claim, and identify the written instrument, if any, that forms the basis of the claim. RESPONSE: ! V A THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 07-745 CIVIL TERM W THIRD: . At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the Defendant? The scope of this interrogatory encompasses, but is not restricted to, the contents of any bank account(s). RESPONSE: *5 FOURTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: 1 31P O ' -1 FIFTH: 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 in part by the Defendant (or in which Defendant) held or claimed any interest. RESPONSE: I V O SIXTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: 4{ SEVENTH: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which the Defendant had any interest? RESPONSE: !V o THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EIGHTH: . If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: NIA NINTH: At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefore? RESPONSE: , I TENTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount, and state the date of the transfer and the name and address of the transferee(s). RESPONSE: AA? IV I6. ELEVENTH: At any time after you were served, did you pay, transfer or deliver any money or property of the Defendant or to any person or place pursuant to their direction or otherwise discharge any claim of the Defendant against you? RESPONSE: y N0. TWELFTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, in the case of monetary assets, state the amount, and state the date of transfer and the name and address of the transferee(s). RESPONSE: ?(JA- THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. +. THIRTEENTH: 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 and the entity electronically depositing those funds on a recurring basis. RESPONSE: fio. FOURTEENTH: 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, did not exceed the amount of the general monetary exemption under 42 PaC.S. Section 8123? If so, identify each account. RESPONSE: INO t)h CMA Y'W CLCCOLkn 0, ntqa--h V Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. DATE: By- Cz teC_ CATHY ANN CHROMULAK, ESQ. MAUREEN A. DOWD, ESQ. CHRISTINE A. SAUNDERS, ESQ. BETH ARNOLD HOWELL, ESQ. 375 Southpointe Boulevard 41h Floor Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r -- nz Q "? SHERIFF'S RETURN - GARNISHEE ? + CASE NO: 2007-00745 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS BOLDOSSER DONNA J And now RICHARD SMITH ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:00 Hours, on the 12th day of June , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named GARNISHEE ADAMS COUNTY NATIONAL BANK hands, possession, or control of the within named Garnishee 1 WEST BIG SPRING AVE NEWVILLE, PA 17241 Cumberland County, Pennsylvania, by handing to HOLLY BONNER (SALES & SERVICE personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . in the true and made Sheriff's Costs: So answ s• Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 . 0 0 ? ?l%/a?• 06/12/2007 Sworn and Subscribed to before me this day of By u y Sheriff ep A.D SHERIFF'S RETURN - GARNISHEE ? r CASE NO: 2007-00745 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS BOLDOSSER DONNA J And now RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:22 Hours, on the 12th day of June , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named GARNISHEE , F & M TRUST in the hands, possession, or control of the within named Garnishee 800 E HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to LACI JEAN HETRICK (TELLER) , 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: So answ ?a•?+w/+C Docketing .00 Service Affidavit Surcharge Sworn and Subscribed to .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 00 / G?I3/d7 ` , 06/12/2007 before me this day of By A.D SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-00745 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS BOLDOSSER DONNA J And now RICHARD SMITH ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:05 Hours, on the 12th day of June , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , BOLDOSSER DONNA J hands, possession, or control of the within named Garnishee FARMERS NATIONAL BANK 37 CARLISLE ROAD NEWVILLE, PA 17241 Cumberland County, Pennsylvania, by handing to CHERYL SHUGHART (SERV. MANAGER in the personally three copies of interogatories together with 3 true and attested copies of the within COMPLAINT & NOTICE the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge and made So-#a,` .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 / Q . 00 06/12/2007 Sworn and subscribed to before me this day of By A.D ,? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL DIVISION: No. 07-745 CIVIL TERM VS. DONNA J. BOLDOSSER, Defendant, TYPE OF PLEADING: and FARMERS NATIONAL BANK, Garnishee, and ADAMS COUNTY NATIONAL BANK, Garnishee, and F&M TRUST, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Garnishee THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Praecipe to Discontinue Against Garnishees, ADAMS COUNTY NATIONAL BANK and F&M TRUST ONLY TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 CHRISTINE A. SAUNDERS, ESQ. PA ID NO. 203373 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 41h Floor Canonsburg, PA 15317 (724) 916-2400 .• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION: Plaintiff, No. 07-745 CIVIL TERM VS. DONNA J. BOLDOSSER, and Defendant, FARMERS NATIONAL BANK, Garnishee, and ADAMS COUNTY NATIONAL BANK, Garnishee, and F&M TRUST, Garnishee PRAECIPE TO DISCONTINUE AGAINST GARNISHEES, ADAMS COUNTY NATIONAL BANK and F&M TRUST ONLY TO THE PROTHONOTARY: Please discontinue this action against the above garnishees, ADAMS COUNTY NATIONAL BANK and F&M TRUST, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By: CATHY ANN CHROMULAK, ESQ. MAUREEN A. DOWD, ESQ. BETH ARNOLD HOWELL, ESQ. CHRISTINE A. SAUNDERS, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard &h Floor Canonsburg, PA 15317 Sworn to and subscribed Before e hs I W day of , 2007. _ THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY Notary blic INFORMATION OBTAINED WILL BE USED FOR THAT COMMONWEALTH OF PENNSYLVANIA PURPOSE. Notarial Seel Heather L. Hatfield, Notary Public Ced Twp., Washington County My Commission Expires June 29, 2010 Mem"r, Pennsylvania Assorlatior of Notaries ' CERTIFICATE OF SERVICE I, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Discontinue Against Garnishees, ADAMS COUNTY NATIONAL BANK and F&M TRUST Only was served upon the following by First Class Mail, postage prepaid on this 18th day of July, 2007. EDWARD G. PUHL, ESQ. 220 BALTIMORE STREET GETTYSBURG, PA 17325 F&M TRUST 800 EAST HIGH STREET CARLISLE, PA 17013 DONNA J. BOLDOSSER 28 FAIRFIELD STREET NEWVILLE, PA 17241 athy Ann Chromulak, Esq. Maureen A. Dowd, Esq. Beth Arnold Howell, Esq. Christine A. Saunders, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. b* C7 d (?'' op C _...? f f a11? ? ? m 4j -c cT'• ., ,,IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, VS. DONNA J. BOLDOSSER, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Plaintiff, Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION: No. 07-745 CIVIL TERM TYPE OF PLEADING: Praecipe to Satisfy Judgment TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 CHRISTINE A. SAUNDERS, ESQ. PA ID NO. 203373 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 0 Floor Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, vs. DONNA J. BOLDOSSER, Plaintiff, Defendant. CIVIL DIVISION: No. 07-745 CIVIL TERM PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please satisfy the judgment against DONNA J. BOLDOSSER, at No. 07-745 CIVIL TERM, and mark the docket accordingly. Sworn to and subscribed Before me this _LO' day of , 2007. "- V- Notary P lic COMMONWEALTH OF PENNSYLVANIA Notarial Seal F Heather L Hatfield, Notary Public Cecil Twp., Washington County My Commission Expires June 29, 2010 M;)Mbx, Penn3ylvsni- Association of Notaries Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By: T om. ©(,A-? i6el CATHY ANN CHROMULAK, ESQ. MAUREEN A. DOWD, ESQ. BETH ARNOLD HOWELL, ESQ. CHRISTINE A. SAUNDERS, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4'h Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy Judgment was served upon the following by First Class Mail, postage prepaid on this 18th day of July, 2007. DONNA J. BOLDOSSER 28 FAIRFIELD STREET NEWVILLE, PA 17241 Cathy Ann Chromulak, Esq. Maureen A. Dowd, Esq. Beth Arnold Howell, Esq. Christine A. Saunders, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r•a in ? 00 „ M 24 W N W 00 t3 + oo! 0 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: ?A-!-. Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL Advance Costs: 250.00 Sheriff's Costs 207.90 18.00 42.10 4.08 .50 2.00 Refunded to Atty on 03/25/08 16.32 80.00 60.00 l.I alL. 27.00 n 207.90 V 'pqpf So Answer, R. Thomas Kline, Sheriff By ? b o l V !' NOP L GOZ 2 J'j 60 5 ?dk--63573 /, aomy IZP WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-745 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From DONNA J. BOLDOSSER, 28 FAIRFIELD STREET, NEWVILLE, PA 17241 (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 FARMERS NATIONAL BANK, 37 CARLISLE RD., NEWVILLE, PA 17241 -- ADAMS COUNTY NATIONAL BANK, 1 WEST BIG SPRING AVE., NEWVILLE, PA 17241 -- F&M TRUST, 800 E. HIGH ST., CARLISLE, PA 17013 -- GARNISH ANY PROPERTY OF THE DEFENDANT IN THE NAME OF THE GARNISHEES 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 $8,606.12 Interest $87.23 Atty's Comm % Arty Paid $135.06 Plaintiff Paid Date: MAY 30, 2007 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs L/c}JuLy REQUESTING PARTY: Name BETH ARNOLD HOWELL, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 203606