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Home My WebLink About03-2130IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, vs. DENISE VASSIL, Plaintiff, Defendant. CIVIL DIVISION ,2130 Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Defendant's Address: 439 North 2nd Street Wormleysburg, PA 17043 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, VS. Plaintiff, CIVIL DIVISION No. DENISE VASSIL, Defendant. NOTICE TO DEFEND YOU F AVE 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 SEOULD TAKE TEIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT ~IAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPEONE TEE OFFICE SET FORTE BELOW TO FIND OUT W-~ERE YOU CAN GET LEGAL KELP. CUMBERLA/~D 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. DENISE VASSIL, Defendant. CIVIL DIVISION No. COMPLAINT AND NOW COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, by its Attorneys, Mollica & Murray, with its Civil Action Complaint, the following of which is a statement thereof: 1. HOUSEHOLD FINANCE 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. DENISE VASSIL is an adult individual residing at 439 North 2nd Street, Wormleysburg, PA 17043. 3. On or about May 13, 2002, 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. 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 Agreement for failing to make payments when due, with the last payment having been made on or about November 9, 2002. 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 Six Thousand Nine Hundred Thirty Six and 79/100 ($6,936.79) Dollars as of March 26, 2003. 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 recover costs of collection and reasonable attorney's fees. W~EREFORE, Plaintiff claims damages in the sum of Six Thousand Nine Hundred Thirty Six and 79/100 ($6,936.79) Dollars, with interest thereon at the rate of 25.698% from March 26, 2003, plus court costs and attorneys' fees. Respectfully submitted, MOLLICA & MURRAY By: CATHY ANN CHROMULAK, 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. ii L: i {IMG:HFCVFR} In this Agreement'you" and 'your' mean the ioon~,eer and co-bom~ver (if any) who sign this Account Opena~ Chec~. 'We.# 'us,' and 'oLir' i~fer th Household Rnance Consumer Discount Compmly ('Household'). if you accept our Personal C, mdit Line Account Offer, this Agreement Personal Credit Line Account Agreement-Fixed Rate DEFAULT AND CANCELLATION OF AGREEMENT. We have the ~ight to require you to pay APR 25 2003 10:52 FR MOLLICA AND MURRAY 4123817111 TO 8510400000009190 VERIFICATION I, Carol Y'Deen, Recovery Specialist for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, a Household International Company verify that the facts set forth in the foregoing Complaint are tree and correct to the best of my knowledge, information and belief, and that I am authorized to verify such Complaint on behalf of HOUSEHOLD I understand that false statements herein, are made subject to the penalties of 18 Pa. C:S. 4904 relating to unsworn falsification to authorities. Carol Y'D~n Dated: May 2, 2003 SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-02130 p COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS VASSIL DENISE R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT VASSIL DENISE unable to locate Her COMPLAINT & NOTICE in his bailiwick. but was He therefore returns the the within named DEFENDANT , VASSIL DENISE 439 NORTH SECOND STREET WORMLEYSBURG, PA 17043 DEFENDANT,S CURRENT ADDRESS IS 6589 WATERLEVEL HWY CLEVELAND, TN 37323-8761. , NOT FOUND , as to Sheriff,s Costs: Docketing 18.00 Service 11.04 Not Found 5.00 Surcharge 10.00 .00 44.04 So answers omas Kllne Sheriff of Cumberland County MOLLICA & MURRAY 05/08/2003 Sworn and subscribed to before me this /~ ~ _, _ day of ~ ~ ~03 A.D. onotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL DIVISION No. 03-2130 VS. TYPE OF PLEADING: DENISE VASSIL Defendant. Praecipe to iDiscontinue Without Prejudice TYPE OF CASE: Civil Action Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 FILED ON BEHALF OF: HOUSEHOLD FINANCE 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 Tfimo~ Plaza 1305 Grandview Avenue Pi~sburgh, PA 15211-1205 (412)381-7000 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 COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. DENISE VASSIL Defendant. CIVIL DIVISION No. 03-2130 PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO: The Prothonotary: Please discontinue without prejudice the above-captioned action and mark the docket accordingly. Respectfully submitted, MOLLICA & MURRAY PA ID NO. 42067 MICHELLE D. SMITH, ESQUIRE PA ID NO. 74800 Attorneys for Plaintiff 1305 Grandview Avenue 450 Trimont Plaza Pittsburgh, PA 15211-1205 Sworn to and subsc, zri. b. ed Befo/e ~e, this a~0~ day of t_~')/Ox&. ,2003. Notary Public I Michelte L. Wolota, Notary Public I [ Pit~sbur. ~ h, Allegheny County. IMy Com,m, iss!on Expires May 17, 2004 Me,m~m- ?,;,- -h~;,,,3,~i~; A~soc aiiot~ o~ Notaries THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Michelle D. Smith, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a tree and correct copy of the foregoing Praecipe to Discontinue without Prejudice was served upon the following by First Class Mail, postage prepaid on thi~f>,D day of MAY, 2003. DENISE VASSIL 6589 WATERLEVEL WAY CLEVELAND TN Mich~l[e D. Smith, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ii