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Home My WebLink About00-05238 .0,," ..~, , .. -, l .' "; p, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. KENDALL LEHMAN, Defendant. Defendant's Address: 52 S. High Street, Newville, PA 17241 CIVIL DIVISION No. 00- S'~JP Ci()~t 'T~ 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 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA & MURRAY Firm #952 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 (412) 381-7000 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE ,'~" " "':; l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. Plaintiff, vs. KENDALL LEHMAN, Defendant. 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 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. '. ~ "~~ -" 11;,'! " IN THE COURT OF COMMON PLEAS OF BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO.iJ-().5.23~~ "l~ vs. KENDALL LEHMAN, Defendant. COMPLAINT AND NOW COMES, the Plaintiff, BENEFICIAL CONSUMER DISCOUNT COMPANY , by its Attorneys, Mollica & Murray, 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 situate at 2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred to as .Plaintiff". 2. KENDALL LEHMAN is an adult individual residing at 52 S. High Street, Newville, PA 17241. 3. On or about August 5, 1999, Defendant entered into a Loan Agreement with the Plaintiff, a copy of which is attached hereto as "Exhibit A" and incorporated herein. 4. Pursuant to the Agreement with Defendant, Plaintiff advanced funds to the Defendant. 5. Defendant is in default under the terms and conditions of the aforementioned Agreement for failing to make payments when due, with the last payment having been made on or THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .. ~ ''*' about December 13, 1999. 6. Pursuant to the terms of the 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 FOUR THOUSAND, FOUR HUNDRED NINE and 86/100 ($4,409.86) DOLLARS as of May 31, 2000. 7. Numerous demands have been made upon Defendant by Plaintiff, but Defendant has failed or refused to pay. 8. Pursuant to the Agreement, Plaintiff is entitled to reasonable attorney's fees. WHEREFORE, plaintiff claims damages in the sum of FOUR THOUSAND, FOUR HUNDRED NINE and 86/100 ($4,409.86) DOLLARS, with interest thereon at the rate of 23.268% from May 31, 2000, plus court costs and attorneys' fees. Respectfully submitted, MOLLICA & MURRAY By: ~Q&,~ CA HY ANN CHROMULAK, E . PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 Attorneys for Plaintiff 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. " "", "-J ,~" ,j, ,.," - LOAN REPAYMENT AND SECURITY AGREEMENT (Page I of 3) LENDER (called "We", "Us", "Our") BENEFICIAL CONSUMER OISCOUNT COMPANY 419 STONEHEOGE ORIVE SUITE 2 CARL!SLE PA 11013 BORROWERS (called "Vou", "Your") LEHMAN. KENDALL SS# 1154B5132 PO BOX 55 41 RUN RD CRLSL NEWVILLE PA 11241 LOAN NO: 111115-105254 EfFECTIVE DATE fiRST PAYMENT DUE DATE OB/0511999 09/05/1999 fOUL OF PAYMENTS AMOUNT FINANCED . 5,122,92 3.916,89 TOTAL FINANCE CHARGE SCHEDULED INTEREST 1.146,03 LIfE INS PREMIUM YOU ARE GIVING US A SECURITY INTEREST COVERING: INSURED YEAR DESCRIPTION MAKE/MODEL SERIAL NUMBER N 1999 PER PROP SEE ATTAT SEC 1 R.EQUIRED INSURANCE. You must obtain insunoco for tClrm of loan covering security tor this loan as indicated below. Daming Us as Loss Payee: Title insurance on real estate security. Fire Bnd extended coverage insurslI:ca on rea) es1ate security, Physical damage insurance on vehicle listed under "SecurityM above if .V. appears under ,"Insured". Physical damage insurance OJ:!. other property listed under MSecurity" above if "Y" appears under "InsuredM. You may obtaio. any required insurance from onyone you choose. (See "Security" paragraph above for description of security to ~ insured,) NOTICE: THE FOLLOWING PAGES CO~AIN ADDITIONAL CONTRACT TERMS. 10-17-98 NAE PAB75001 OAIG'NAL 1IIIIDIIUIIII~~II,.tl,WI!ll~1 ,. . ~ ,., ~ ,,~C_ ,~, , " 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 Am~unt 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 a,ddress as stated on page one 01: 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. PAy-oUTS, You agree to pay-outs of Amount Financed as shown on Truth-In-Lending disclosure form, If pay-outs 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 pay-outs. 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 781hs." 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 1/2% per month on the amount overdue (subject to a $1.00 minimum charge). BAD CHECK CHARGE. We will charge you a.feeof $2lJ if any payment check is returned because of insufficient funds or is otherwise dishonored. You agree that we may deduct this charge from ti 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, EXCI1ANGE 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 8602, Elmhurst, IL 60126, 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. OPTIONAL INSURANCE. Optional Credit Insurances and any required insurance disclosures are attached to this Agre<>ment and are incorporated herein by reference. APPLICABLE LAW. The Pennsylvania Consumer Discount Company Act (COCA), Title 7, Purdon's Pennsylvania Statutes, governs this loan. NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS. 10-17-98 NRE PAB75002 ORIGIN<\L IllmIIUIIIIIUllmlmllllllllllllffiIUIIIIIIU~IIIIIIII~~ ~ . , on, . ., --- '~ ---, 'l:m LOAN REPAYMENT AND SECURITY AGREEMENT (Page 3 of 3) .' . I YOU HAVE RECEIVED A COMPLETE COPY OF THIS AGREEMENT AND THE TRUTH-IN-LENDING DISCLOSURES. BZZ~RJ'~ ~ 4-f (SEAL) (SEAL) (SEAL) WITNESS: rKQmQ ~ ~ N'-() N'rIa.1> 10-17-98 NRE PAB75003 ORIG'NAL 111.lllml~WIIUllilll~~llllml ,-" ,-, ,- ", ~ "'W-e' VERIFICATION Latoshia Williams, Recovery Specialist for BENEFICIAL CONSUMER DISCOUNT COMPANY, a HOUSEHOLD INTERNATIONAL COMPANY deposes and says subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities, that the facts set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. uJc9:Z;'h;'~ ;afi!'lli~ltlili.llii:i;JjjllmiMIM~:;',&,o'}'ili-,~,~~W:I@i~"!~,i\:;w,,,",,,.,~;!&;iill'Di;!~"..ililI~~'Rt~ ~~'~Ujjjf.il' t1r~'. ~"'"""'"~'"""-. J~ " ~.. iirfiii ~lir ~-i riOO~"""-;:t ,I ~ ~ t ~ 0 .vi ~ C.:J () [.: c:) ,.-", t:T Q ~ B . '- "J] I/) .() 0 (y ,'''- -,- ..() 0 C\, I I -r- '-'.:' 0" ' '-,~? 0 ....J ~'C':.j ft _. -0 ~ ~ ~5~) '. J ( ~ ,;-;J ~ -> -ft ~- i,J' _._1 :~) ~' (:::.... ~.i ) -, . "~'~-" .'.._,' ~,~~."~'-'~~-'~-~-"'" ~,. ~,'^; ,-" , . ,,~ "~ ~~ ,,~ "' "~i6l<<~! SHERIFF'S RETURN - REGULAR CASE NO: 2000-05238 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS LEHMAN KENDALL WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LEHMAN KENDALL the DEFENDANT , at 0015:25 HOURS, on the 4th day of August , 2000 at 52 SOUTH HIGH STREET NEWVILLE, PA 17241 by handing to KENDALL LEHMAN 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 Service Affidavit Surcharge 18.00 7.44 .00 10.00 .00 35.44 So Answers: ~~~t'~~~ R. Thomas Kline 08/07/2000 MOLLICA & MURRAY Sworn and Subscribed to before BY'~ ,De (heri f ,11:- me this /e, ~ day of (),~~ A.D. , (2 /Yu';" "~ rothonotary >,," \" '1 ffiI~ - M"'V'~''''~- ~'ilIi'ii~l"~IilIrjlJ_~-~- ,,, ~', ^ _ _"t :' '. ,,~ , - ~~l~* .._-, ~~ .,," ""'='"" JiliJt'i"'.~l '''<_i ~ . , < ~ ."" "~- , ~ ~'-'-.4I--'IlIIIMJ-L ~ ,J -" , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 00-5238 Civil Term Plaintiff, TYPE OF PLEADING: vs. KENDALL LEHMAN, Praecipe for Default Judgment Defendant. TYPE OF CASE: CIVIL ACTION FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Defendant's address: 52 S. High Street Newville, PA 17241 CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA & MURRAY FIRM #952 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 (412) 381-7000 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE Wm ',,",",," ~'- .......-'"~1lis:;':it~1ll\h3li-jj!I!di!liilIij,ijliijjjlj~~~~~Ji!J~~~ ~--' .~ > -1iIIIIIiII - --""'r~~ ~^ : ~ '.... . " () 0 0 c 0 -r. s:: Z :-:::1 -Oct} Cl tH;9 mm ,-- z::u , E~i 6i s:; r...,; -.<~. kG -0 ::T~-:f..t ~o J: ()(-) -0 N (5rn >c "'" ~ trl 15 (,.) -< - ~" , ~- ""'~"',_~ . r' , TO: PROTHONOTARY Please enter judgment defendant, KENDALL LEHMAN, follows: by default against the within-named for failure to file an Answer as Amount claimed in Complaint: $4,409.86 Interest from 5/31/00 thru 10/31/00: 259.36 Costs of Collection thru 10/31/00: 654.50 TOTAL 5,323.72 with interest accruing on the total balance of $5.323.72 at the rate of 6% per annum, together with additional costs of suit. By: 1/1l;i-J!;J~) 1Z CATHY ANN CHROMULAK, ESQUIRE MICHELLE D. SMITH, 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 ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared MICHELLE D. SMITH, 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 knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed to defendant on October 18, 2000 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attached copy. @d/Lt /J /m/ r( CATHY ANN CHROMULAK, ESQ. MICHELLE D. SMITH, ESQ. Sworn to and sUb~be~re me this 2L day of '~ 2000. ~~~ .otary Public THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE Mpl"~~' ....-.,~ ,I",,",,;,., ^<:-<;:.-,,.btinl1 nf Mnt:-'lriA'" '-"-~"~"'-';-"'~~iIi_l!iIt!""'if!l~~~~~~! ~~ ~~~t"';"'" "- .- - --- . """ ' .'" 0 Q 0 C 0 -c) :5:: - -vC'J) C5 mm .c.-::;: Z:D ..~? ZC I ::QJeC N 4C. >:!:CJ ~C:i " ~,- ,. )>C' :x; ~\:Jj 26 .:;.:;;C) '''' '~~rn S>c: O' ~ ~ ::J1 ~ (.J -< . ~ ,- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. 00-5238 Civil Term vs. KENDALL LEHMAN, Defendant. TO: KENDALL LEHMAN 52 South High Street Newville, PA 17241 DATE OF NOTICE: October 18, 2000 IMPORTANT NOTICE you. ..ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRIT.ING 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 BAR.ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 800-99G-9108 By: /JUA,ft /74171 CATHY ANN CHROMULAK, ESQ. MICHELLE D. SMITH, ESQ. Attorneys for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE """"'~- ~-.,,.Jf<^"'~~"""i~ij@;iii~Hti~~il~~UU~~'!!!I~ ~ , - ... . 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'-., "' ~ ~~ ,"" 0 0 0 ~ <:::) ,', ~: $. % ~. ~J "UQ.i ::::> mrn .0: f-'::: Z:Il I -"iT! ~ ...... ~ '\ zs: t,) ...1.')1.::; I:') ::Q -/' ".)(") IN ~ kl'J -0 :_.$~ , :PC :x ~ ~ Z~' -u r;.? (:>fTl ~ Pc: ~ Z ::J1 'j;! =< :n (,,) -< i ,_ "~'""~_ h~~" ^' ",_ " "" . _~ - '" ^ _~. 0." .~, .~.~~. -~'-" ~ ~~~ ~.- -- , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER D1SCOUNT COMPANY, No. 00-5238 CIVIL TERM Plaintiff, vs. TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION KENDALL LEHMAN, Defendant, FILED ON BEHALF OF: and BENEFICIAL CONSUMER DISCOUNT COMPANY FARMERS & MERCHANTS TRUST CO., Garnishee. COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA & MURRAY Firm No. 952 1305 Grandview Avenue 450 Trimont Plaza Pittsburgh, PA 15211 (412) 381-7000 TIllS IS AN AlTEMPT TO COlLECT A OEBT ANO ANY INFORMATION OBTAINED Will. BE USEO FOR THAT PURPOSE. ,~,,",,;"H .~ _, ~=~~,~"' '"= ~ ~ 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, No. 00-5238 CIVIL TERM Plaintiff, vs. KENDALL LEHMAN, ~ ~ S"'oc.d-l... {./., 'it.. r.+- A>~u'~ Defendant, ~tJ. '?:2.L(( and FARMERS & MERCHANTS TRUST CO., Garnishee. PRAECIPE FOR WRIT OF EXECUTION TO: The Prothonotary please issue a Writ of Execution in the above matter, 1. directed to the Sheriff of CUMBERLAND County; 2. against KENDALL LEHMAN, defendant, and 3. against FARMERS & MERCHANTS TRUST CO., garnishee, 4. and index this writ a. against KENDALL LEHMAN, defendant, and b. against FARMERS & MERCHANTS TRUST CO., garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendants in any accounts. individual and ioint. personal and business. 5. Amount of Judgement Additional Interest to Date (Costs to be added) $ 5,323.72 $ 119.26 $ Pursuant to Writ of Execution and Service of Writ $ 5,442.98 1(fI,JJ,t () frn I A. MICHELLE D. SMITH, ESQ. THIS IS AN ATIEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . ~~;/!'1~:iffil...d6,".4 I .-, . ')1 !..;,~"". '~MJ1Sl~L~ If!Ii. 'Ii' . ~~II~iiti~l!. d,_,,,"'<ib;d&;!iliIili:,,~~w>!j;~.',;j;;;;flIi,,,"%1l!&lifl'I'; , ,;"kC.d~,i;!:;'{jl_\"""~,i...,b;ikill"'i;;lco."'"" ~iMim. "",.~ f ..... -k~ Co ~ ~ 0 0 0 (.) -...J )J .0 (;:, c .. ~ 6-.~ -F . . . ? s ::;;: 1 . :-.... d a ~ -l: 0 -orL :;;:-,.. ~'. l ~ ~ 8 fTlP"" ;;:0 .._.,\~\, '" C < 2 -r 0 2 ~: N :UC;:I I I ~ ' '\ ~ I (/)$'-"" "--"~C) , -<..-:: ~:~:B 0\- r ~c -0 ~ >-- Q\ ~ ~! -- ~c - :::-_.0 0{) - ^ S>~ 6{n ..t . r.:: - , ~ .-.-{ ..". " ~ ~ , z: """ :TI f , =< - ~ -< , , ... , ~ ... ., F;' r .~ ~. _W ~.n~", ~" ~ ~." " _. ,~ fI .~Li ,j " 'I , J I II :1 , , :i i I , , , " :J1!+1" SHERIFF'S RETURN - GARNISHEE <.;. CASE NO: 2000,05238 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS LEHMAN KENDALL And now BRIAN BARRICK ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 1420:00 Hours, on the 28th day of March , 2001, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT LEHMAN KENDALL , in the hands, possession, or control of the within named Garnishee FARMERS & MERCHANTS TRUST CO 3 EAST FIRST STREET BOILING SPRINGS, PA 17007 Cumberland County, pennsylvania, by handing to LYNN L. NETZEL, CUSTOMER SERV- ICE REP. person~lly three copies of interogatories together with THREE true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge So a~~ .00 .00 .00 .00 .00 .00 R. Thomas Kline Sheriff of Cumberland County this if ~ day of ()!,,,-.e d1kJ A.D. , ,~QL ~, Pro bhnotary , ~ 00/00/0000 J?'" n J. me By 1~ 7th I~ Deputy Sheriff Sworn and subscribed to before -~.- ~_.'. .~ ~ ~ -~".' ~ "> I ,. :f\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, No. 00-5238 CIVIL TERM Plaintiff, vs. KENDALL LEHMAN, Defendant, and FARMERS & MERCHANTS TRUST CO., Garnishee. TO: FARMERS & MERCHANTS TRUST CO. 3 E 1ST STREET BOILING SPRINGS, PA 17007-9601 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. A:.s~ -b INTERROGATORIES TO GARNISHEE FIRST: At the time you were served or at any subsequent time did you owe the Defendant(s) any money or were you liable to them on any negotiable or other written instrument, or did they claim that you owed them any money or that you were liable to them for any reason: RESPONSE: Yes 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: $314.92 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,-""".. I * , " 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(s)? The scope of this interrogatory encompasses, but is not restricted to, the contents of any bank account(s). RESPONSE: No 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: No 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(s) (or in which Defendants) held or claimed any interest. RESPONSE: No 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: No SEVENTH: At the time you were served or at any subsequent time, did you hold as fiduciary any property in which the Defendant (s) had any interest? RESPONSE: No THIS IS AN ATTEMPT TO COLlECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ..",;;j_"",',-,,,J",,," -._~~ . -~"~. - , U'~:" ~ " 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: No NINTH: At any time before or after you were served, did the Defendant(s) 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: No TENTH: 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 the transfer and the name and address of the transferee(s) RESPONSE: No ELEVENTH: At any time after you were served, did you pay, transfer or deliver any money or property of the Defendants (s) or to any person or place pursuant to their direction or otherwise discharge any claim of the Defendant (s) against you? RESPONSE: No TillS IS AN ATIEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TIlA T PURPOSE. 0i~ ,~,. - ... . ~. 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: No Respectfully submitted, MOLLICA & MURRAY Date: 3~ By: C{!l,JJJ,f) t~h~ Cathy n Chromulak, E q. Michelle D. Smith, Esq~ 1305 Grandview Avenue 450 Trimont Plaza Pittsburgh, PA 15211 (412) 381,7000 ".;,' . < . THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,~~ ~"~'''"k" ~~5~}j51~",!I~.io"","'I';"" ",,,,,,I,,, !~':O;;&iE6k!l;.~M~"",-"''-",-''',""1''$K'''-''lijh,":'''f,'~,'b'i"-iji,,,i0'~;;''li~<!!"Mi!wj.l;,:.,iliiIl~i;ij~~~ . ~'~'6'~"""-~Ji:i:jlli1 < "-~='W'- ~~iiIIj ~ ~ ~ ~, eea ~ ~ ij .---'>' ~],,,'" ii i! ii i: " :i , "I ,.~~" "~ . - g-',,: , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, No. 00-5238 CIVIL TERM vs. KENDALL LEHMAN, Defendant and FARMERS AND MERCHANTS TRUST CONWANY OF CHAMBERSBURG, Garnishee CERTIFICATE OF SERVICE I certify that I delivered true and correct copy ofthe Defendant's Answers to Interogatories by Farmers and Merchants Trust Company of Chambersburg by personal service on April 18, 2001. Michelle D. Smith, Esquire 1305 Grandview Avenue 450 Trimont Plaza Pittsburgh, PA 15211 Kendall Lelunan 52 South High Street Newville, P A 17241 JkP rA1!J;tJ// Sandra G. Small, Esquire Attorney for Farmers and Merchants Trust Company of Chambersburg PA LD. #82044 ,,,'1 ~ ~~ '. ". COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) ......-" -;"-", Farmers and Merchants Trust Company of Chambersburg, being duly sworn according to law, deposes and says that the answers set forth to the foregoing Interrogatories are true and correct, partly upon personal knowledge and the remainder upon information and belief. Sworn to and subscribed before me this Ifill day of ~ ,2001. ~~ Notary Public ~ Notarial Seal Robin N. BenctIofl, NoIary Public Chambersburg Boro, Franklin County My Commission expires Mar. 7, 200S Member. PennsylvanlaAssoclationotNolarle$ Farmers and Merchants Trust Company of Chambersburg ~ ~~~~'''?'7",:;,"-_,-",~,;"""''''''~W"""~'i&iW;",,,,,~-jl~;,,",~_~lllill~~ilIUfllllil."-' ,_"."w~"'_ ~_? .~ ... " -, ~~' "lillIl!J.' ~~ ~l[ - " .. .....~ i 11 II C) C'; () C- , -;, ~.J f. n' ,. -- :1 , - / c \-,.C) U? r~.: ~'G --,' >. L._ :;) .. ~.--j -..::: .1~ - ''''-'''_="~~'''''''''''''''"",,",''O ", .. '............- . [""," IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs KENDALL LEHMAN, Defendant, and FARMERS & MERCHANTS TRUST CO. Garnishee. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 00-5238 TYPE OF PLEADING: Praecipe for Judgment Against Garnishee TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA 6< MURRAY FIRM #952 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 (412) 381-7000 ~~l;'!i~rt"';~''iffi-,,-'-'i~'lfI:~~_~~~~tji~~lm~':i/Ii''0~H~/''''--- ~.- lll&:t\liill'~":" - ~ .'"'ir:i< ill 'Q i~ II ],j '-" I! ,'I I;, " II ; i Iii Iii ""'-"" ""'~i>L.. ~ll!ii1il.!!Ii."lJ:!.;t;"" ", .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, No. 00-5238 Plaintiff, vs KENDALL LEHMAN, Defendant, and FARMERS & MERCHANTS TRUST CO., Garnishee. TO: PROTHONOTARY Please enter judgment against Garnishee, FARMERS & MERCHANTS TRUST CO., in the amount of $314.92 based upon the Garnishee's Answers to Interrogatories attached hereto "Exhibit A" admitting possession of funds of Defendant in that amount, which is less than Plaintiff's judgment against the Defendant, interest and costs. Mollica & Murray 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 By: ~Adt () Mi/lL Cathy Ann Chromulak, Esquire Michelle D. Smith, Esq. Attorneys for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ",."""~=>""~~ko' _~ - ~~~ ""''''''''''"",,',",,', ., .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 00-5238 Plaintiff, vs KENDALL LEHMAN, Defendant. and FARMERS & MERCHANTS TRUST CO., Garnishee. NOTICE OF ORDER, DECREE OR JUDGMENT TO: ROBIN N. BENCHOFF CREDIT ADMINISTRATION FARMERS & MERCHANTS TRUST CO. P.O. BOX "T" CHAMBERS BURG , PA 17201-0819 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on . )/,,)!" 7. ::i,ry,/. , ' () A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $ 314.92 plus interest at the rate of 6% per annum and additional costs of suit. '--- Mo~ -P .7?~~r----- Deputy THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. ~~~.i."t'f~fF.;:'-'ii&!'i'ili;'ffiji%:~cM;'"'~~lt;~\'i'"~k1!~~~t~.,M!fl:l.iW,'ffilf""'~';;'f?"'%oI""~~i".,....;,.~".'~liliil..~"~-llfC1HIi;!.........,--~ IiI'iII -, JlWlJ ,,-~ . ~ '1 I I [ '._'''"r~ - I, " THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~". --~;", CERTIFICATE OF SERVICE KENDALL LEHMAN 52 SOUTH HIGH STREET NEWVILLE, PA 17241 /)1!,4wtt iJ hn, ~ Michelle D. Smith, Esq. . _1J~~~~~ltf.,.m~'i2>j~jj;-,i.<!~~im:Jl!~~~tli~m'iifilil.lio!lilih!'ii1W*li~f<)<~~1IiiBtl "'liIa~~'~~ '''IIIIIIlII.~lJ: ''',~. .,~~~,..-,- ~liI -' ~ ~ ~t~. .' "......,'! ~ . '" 0 <=> 0 C -n ~ 2" L- .-{ n .~ l (0 -om c= I-n ...0 rn IT: :;~ IT'-:p '[ 2:0 t ZI)=: I -nm 8 . "'1' ~;~:: -.I 75 r:::CJ -,-\~) -0 -t- " (1 )>..-., 3.: <5:n Zt) ::7('":1 r '- ~ U ':: 7Srn )>'C ~ ..... f Z .::;) ~ ~ '" :< (:0 ~ f"" ...J & 1::. ~ 1- '" ~ '.' ~. .^W "_" -".."..,. .,_~ .~. ,,~,' -.,.".'. , ---,--"""--"","".,,,,~"~ - ~~' -iIillll - " "O""~: ,.,. .... ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, No. 00-5238 CIVIL TERM Plaintiff, vs. KENDALL LEHMAN, Defendant, and FARMERS & MERCHANTS TRUST CO., Garnishee. TO: FARMERS & MERCHANTS TRUST CO. 3 E 1ST STREET BOILING SPRINGS, PA 17007-9601 You are requiFed to file Answers to the fOliowing interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. INTERROGATORIES TO GARNISHEE FIRST: At the time you were served or at any subsequent time did you owe the Defendant(s) any money or were you liable to them on any negotiable or other written instrument, or did they claim that you owed them any money or that you were liable to them for any reason: RESPONSE: Yes 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: $314.92 EXHIBIT THIS IS AN ATTEMPT TO COLLECT A OEBT AND ANY INFORMAnON OBTAINED Will. BE USED FOR THAT PURPOSE. ~ " 3 if:\ _""""'4~~_'-O - - ,,,,,' '-!I,lJ\.ililj-, .. ~., THIRD: At the time you were served or at any subsequent time, was there in you~ 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(s)? The scope of this interrogatory encompasses, but is not restricted to, the contents of any bank account(s). RESPONSE: No 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: No 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(s) (or in which Defendants) held or claimed any interest. RESPONSE: No 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: No SEVENTH: At the time you were served or at any subsequent time, did you hold as fiduciary any property in which the Defendant (s) had any interest? RESPONSE: No THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. _"~;,' ,~".,__-.M .~ "', .. ;a, . ., 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: No NINTH: At any time before or after you were served, did the Defendant(s) 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: No TENTH: 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 the transfer and the name and address of the transferee (s). ' RESPONSE: No ELEVENTH: At any time after you were served, did you pay, transfer or deliver any money or property of the Defendants (s) or to any person or place pursuant to their direction or otherwise discharge any claim of the Defendant (s) against you? RESPONSE: No THIS IS AN ATTEMPT TO COUECT A DEBT AND ANY INFORMAnON OBTAINED WILL BE USED FOR THAT PURPOSE. 'li$l~'~ "~." . ~ ~'".. ,~ "--~.. ^ " L._' , ".~" rr~l'-Ic ,. . . , 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: No Respectfully submitted, MOLLICA & MURRAY Date: 3lWh By: @"JJJ() fm1~ Cathy n Chromulak, E q. Michelle D. Smith, Esq~ 1305 Grandview Avenue 450 Trimont Plaza Pittsburgh, PA 15211 (412) 381-7000 ~'-W.;' _b.....' ,.'~." ,. , , THIS IS AN ATTEMPT TO COLLECT A DEBT AIIlD ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. , '" ~ , -,~, , ~O~, "j~<>>i"",,- . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, No. 00-5238 CIVIL TERM vs. KENDALL LEHMAN, Defendant and FARMERS AND MERCHANTS TRUST COMPANY OF CHAMBERSBURG, Garnishee CERTIFICATE OF SERVICE I certify that I delivered true and correct copy of the Defendant's Answers to Interogatories by Farmers and Merchants Trust Company of Chambersburg by personal service on April 18, 2001. Michelle D. Smith, Esquire 1305 Grandview Avenue 450 Trimont Plaza Pittsburgh, PA 15211 Kendall Lelunan 52 South High Street Newville, P A 17241 _ J;}~t<(~IJ// Sandra G. Small, Esquire Attorney for Farmers and Merchants Trust Company of Chambersburg PA LD. #82044 '" ". , COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) '" Farmers and Merchants Trust Company of Chambersburg, being duly sworn according to law, deposes and says that the answers set forth to the foregoing Interrogatories are true and correct, partly upon personal knowledge and the remainder upon information and belief. Sworn to and subscribed before me this I~dayof ~.2001. t.Huj)-j(~ Notary Public Notarial Seal Robin N. Benchoff. Notary Public ChambersbulJl BOlO, FranklIn County My Commission Expires Mar. 7, 200S Member. PennsylvenlaAssocla1ionOlNolarie8 Farmers and Merchants Trust Company of Chambersburg _'~.~w_ ~ '" . ~, , ,l' -- . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DMSION No. 00-5238 Plaintiff, TYPE OF PLEADING: vs. KENDALL LEHMAN, Praecipe to Satisfy Judgment Defendant. TYPE OF CASE: Civil Action FILED ON BEHALF OF: Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA & MURRAY Firm #952 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 (412) 381-7000 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ",'= . :..o,,~ ~ l!l" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. KENDALL LEHMAN, Defendant. CIVIL DIVISION No. 00-5238 PRAECIPE TO SATISFY JUDGMENT TO: PROTHONOTARY Please satisfy the judgment against KENDALL LEHMAN, at No. 00-5238, and mark the docket accordingly. By: Sworn to and Subscribed to before me this '&?day of tz.'.2..~.O.I.. ~ , '. ~ili~ Notary Public . "~ollirlal Seal :M~~ -.-, Pennsy1vanlaASsoctatlOnotNo1aries Respectfully submitted, MOLLICA & MURRAY ~~~)// CATHY ANN C OMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 Attorneys for Plaintiff 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~illfi'~' ,- ~ <W6,il~W!i"'~~"~~~~~~~:lilM';i:~Ilii' ~._.' '~~J.Mm ~ ';.I} .w.., , ~, . " o;,?'~ "H "'It:'- - CERTIFICATE OF SERVICE I, Michelle D. Smith, Esquire, counsel for Plaintiff, 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 United States First Class Mail, postage prepaid on this 21st day of November, 2001: KENDALL LEHMAN 52 South High Street Newville, PA 17241 James Robinson, Esq. Turo Law Offices 28 S. Pitt Street Carlisle, PA 17013 117v1tJ; /)~ Michelle D. Smith, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. - ']j~'"' ~ ....,~ '~ow-lj~_~~ ,,~,- A ' ~. . "-'iIliliii'~_~"" ~ ... -<.--~~~~~~ , "," -..... - ~"" o c <~" "Dijj (1) [f' "'-- ~.._! 2- (f)~-,: -<....-..;.. c:: C) ~C, ~C' S>c: 2 :;j .,~.~ hO~ 000<", ,. "'-'\i - C> o -1"! z C~ "'C:::: " f= -;11;:; ":-~y _.~ ,-, ----< ~._"' :~~ EjM ~ :0 -< 1') (XJ "T.' w (Jl reJ I!dl-, (f!5; = fbIb fbIb ~=-'1) " ,. ~~ < =,~""~< -~?' 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: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Garnishee Advance Costs: Sheriff s Costs: .150.00 83.86 66.14 18.00 1. 64 .50 1.00 3.72 Refunded to Arty on 7/15/02 30.00 20.00 9.00 83.86 ~ I "" t So Answers; "':l ~~..~~ R Thomas Kline, Sheriff . Bt~.Qllti'lollB~4f Sworn and Subscribed to before me this /?~ayof C),Jy 2002 A.D. ~H_ 12 JJu.l;'-',~ pro onotary "..!'J..j ~~-~.~ VINVA1ASNN3d :!lc:!l}1'y:) {{~~;?J ~::.:.--:.:.::::;:1 10, Hd OS Z LZ ilUW 41""". ["- ..-, r;-'--.' ~=:>;, A.1Hn<:0 !,'fiV-'U',~nll J.llll:lH~ 3lH ,40 ;liJIjdO I.SO tI-t.37"'~iS I!u-> /).7 3 5'1 idI_e..it8jililiI1l!j!ftM.~~1.H'3"";6"'''P'N'''!'''iffm.~',I;''HMft''~.?.lJ'~:j"i<~'.l\!:.~-""o..:.:,jHZ:,~g.,::"";ri'i",,,;j;)jf~~~~lI!OiJtii!ijilYiMD~-"._' I.' "",,,,~K"~:ilIlIllIiII~~ZI 'I'''' ,., I I I , WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND} NO. 00-5238 CIVIL 15X TERM CIVIL ACTION - LAW TO THE SHERIFF OF rl1mhp-rl ~nn COUNTY: To satisfy the debt, interest and costs due Beneficial Consumer Discount Company PLAINTIFF(S} from Kendall Lehman, 52 South High St., Newville, PA 17241 DEFENDANT(S} (1) You are directed to levy upon the property of the defendant(s) 2lnd to sell_ (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of R::Il:HlCrs .. Herchants Trm:t Co , 3 E 1st Str....@t, l'oilin9 <=:pr;"'9"', Pl> 17007-%IH GARNISHEE(S) as follows: and to not~y the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any properly of the defendant(s) or otherwise disposing thereof; (3) If property ofthe defendant(s) not levied upon an subject to attachment is found in the pol;session of anyone other thana named garnishee, you are directed to nomy him/her that he/she has been added as agarnishee and is enjoined as above stated. Atty's Comm Atty Paid Plaintiff Paid % LL Due Prothy Other Costs $.50 $1.00 Amount Due $5,323.72 Interest to date _ $119.26 $107.44 Date: March 21. 2001 Curtis R. Long Prothonotary, Civil Division '4 L2o",," ~ '. ~rn/?4'>i,r- Deputy REQUESTING PARTY: Name Michelle D. Smith, Esq. 130:' Grandvlew Avenue Address: 45Q TrimGRt PlaZa Pittsburgh, PA 15211 Attorney for.: Plaintiff Telephone: Pittsburgh, PA 15211 Supreme Court ID No. 74800 - '-' IE . ""';"'~.", .- , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 00-5238 Plaintiff, TYPE OF PLEADING: vs. Praecipe to Satisfy Judgment KENDALL LEHMAN, Against Garnishee ONLY Defendant, TYPE OF CASE: and Civil Action FARMERS & MERCHANTS TRUST CO., FILED ON BEHALF OF: Garnishee. BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA & MURRAY Firm #952 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211-1205 (412) 381-7000 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINEO WILL BE USED FOR THAT PURPOSE. """'" ~ , IN THE COURT OF COMMON PLEAS OF BENEFICIAL CONSUMER DISCOUNT COMPANY, CUMBERLAND COUNTY, CIVIL DIVISION PENNSYLVANIA No. 00-5238 Plaintiff, vs. KENDALL LEHMAN, Defendant, and FARMERS & MERCHANTS TRUST CO., Garnishee. PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please satisfy the judgment in this action against the above garnishee, FARMERS & MERCHANTS TRUST CO. and mark the docket accordingly. By: Respectfully submitted, MOLLICA & MURRAY ~()m~ CATCHRO AK, ESQ. MICHELLE D. SMITH, ESQ. Attorneys for Plaintiff 1305 Trimont Plaza Suite 4504 Pittsburgh, PA 15211-1205 Sworn to and subscribed before me this .;1(;, 9' day of C)c.,--I-vL. , 2001. ~~:=. L~~~4~ C}... Notary Public Notarial Seal Yvonn.e Gardner Jones, Notary Public My PiIIsb~l!lh, AIIElIlheny County CommISSIOn Expires Jan. 29, 2005 Member, Pennsylvania Association of NoIanes THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. """',; r ~ CERTIFICATE OF SERVICE I, Michelle D. Smith, Esquire, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy Judgment Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 2~ day of July, 2001: .21.o~ ROBIN N. BENCHOFF FARMER & MERCHANTS TRUST CO. P.O. BOX 6010 CHAMBERSBURG, PA 17201-6010 KENDALL LEHMAN 52 SOUTH HIGH STREET NEWVILLE, PA 17241 Mic~t~. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. _~iiI'Ji-~~iwg,~~;m;t.2i;l,itll!lt~f~~Il!i!<i@l'Jr,kojf,,"~~~~_i" 1 ........ ........ ..t '-0 () --..Q ~r f.::l .tQ. i ~ ~ () ~p:: -~ -iiIIiillilliiliif"'"~~~' ,', '.,-._~ () c.-=- , ~ "I :..,) (;-', '-, '.'iJ) Ii i! Ii I "(