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Home My WebLink About01-03087 "._-...._"'-~ .L._ _ .. ( - . , ., '10, _.1 'J ~'~il!iil!1i:!,~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. KAY L. SUCCA, Defendant. Defendant's Address: 1 Orrs Bridge Road Camp Hill, PA 17011-1914 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOS~. CIVIL DIVISION e()'LL~~ No. 01 - 3of>7 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 .~.~.-~ << . I ~~Milfj;~~{i '0' ~~ - ,.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. Plaintiff, vs. KAY L. SUCCA, 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. "",,~f'-~~Il:l_ I~i 1.J - .--. -~ ,- -'~ , . ( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION () '., IU- No. 01. 3067 ~ Plaintiff, vs. KAY L. SUCCA, 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. KAY L. SUCCA is an adult individual residing at 1 Orrs Bridge Road, Camp Hill, PA 17011-1914. 3. On or about March 26, 1996, Defendant entered into a Loan Agreement with the Plaintiff, as evidenced by the Affidavit 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. -,-"''''-..-..-,. ~-_.... ~ ,], '- -" . I - ~l~-,_, "- '.j 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 February 12, 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 Two Thousand One and 18/100 ($2,001.18) Dollars as of April 7, 2001. 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. WHEREFORE, Plaintiff claims damages in the sum of Two Thousand One and 18/100 ($2,001.18) Dollars, with interest thereon at the rate of 23.27% from April 7, 2001, plus court costs and attorneys' fees. Respectfully submitted, MOLLICA & MURRAY By: ./f17~ I) 1hz. I rA CATHY ANN CHROMULAK, ESQ; PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 Attorneys for Plaintiff 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. ^ ^'~ ,. ~ - M"_"~ , 00 ,:,.; ,,,-,,,,I __,.'ci ."~' 'J':' ,~ ,~ ~ .,," "'>l;iio< "eri -~', , , -,~',. ';;.i",-,.;$.'';;.,L", -'--"';.<i :,.,'1 0 , Beneficial Finance ~ A Household International Company fA Beneficial" P.O, Box 10640 Virginia Beach. VA 23450 .' , . ( ~__hold IIOIJI'V.- AFFIDAVIT OF LOST NOTE I, the undersigned, do hereby certify that I am the representative of the lender. I further certify that ~olL1, JuCffi~ accoun~-~ Ij fl IDd03 3 executed a revolving note loan agreement dated.Q}O/(O\Cl0with monthly installments. The first being due on ~ ~ to \q lo I further certify that after ~ the said revolving note loan agreement was either lost or destroyed and that there IS presently an outstanding balance of saco 1 ' 18 plus interest at the contract rate of CB 'dfl percent from al ~l 0 I and reasonable attorney fees, if applicable, due upon defau1i) _. r. rl f ""-- ~ Ill!}) (}J U l[h;l(})JJt RECOVERY SPECIALIST Sworn and subscribed to before me thi~ ~~ay of ~ 2001. ~{!.-rMJI.....g~.~4 My commission expires: " EXHIBIT 1-8-- :,~--~:i"-'Ll:ill!f"';'" "". ~ {;5 , - ;.' - ,- ..... -.,'-,'- ''';:';"''-<--'~~.,p~~~~;li'~-=''i.'''l:.\. .. , ~~ ~7 - D.] ~rL. ~!__, ,_~,,~"'.., ,~, ".,_ '__, __""^~"..,, ,~, ,.." _. ._" ,_" _"",~,._ ','l'<'Y! , t<,,'_h" ,~'I,,_, ," c,'., _,~ '_ ..". _ ~_ = ,--,' ,--" 'e-" o . p 6q, "fQ. f ~ ru ~ (') ("~ ~. B ~ c u <,~ " " '-- . . -rJr.i:: :.c:;;,~ .~ B \) It) [fir;- ........ ~?: :'j .::::- v::.l C> () ~S-:~ r...) ;Q -<., -". l , I li~ -0 ~ ~ If' ~J Z ':'~ j~!' ~ .[:"" =0 1- -< "~,; I- '.- -.:~ --~.", ,.4;' ,.'., . " ..' _____,~.,^,'_".~_,",O,,;c,., _N, ,~'" ~~ ,~ ~ "..___~h ,~, N n ,~~""-~,.. " I . ~ .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 01-3087 CIVIL TERM Plaintiff, TYPE OF PLEADING: vs. KAY L. SUCCA, Praecipe to Settle and Discontinue Defendant. 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. "~ "'- 'ID'!il""._,,_, "_~~"."".r ". . .-.-" ~".., _ i .,""""","""i~!-; .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 01-3087 CIVIL TERM Plaintiff, vs. KAY L. SUCCA, Defendant. PRAECIPE TO SETTLE AND DISCONTINUE TO: The prothonotary please settle and discontinue the above-captioned action and mark the docket accordingly. Respectfully submitted, MOLLICA & MURRAY By: c~"1l/4t2~SQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 Sworn to and su~cr~bed b"f~hi" ~day of , 2001. - ~ Not'ary Public Attorneys for Plaintiff 450 Trimont Plaza 1305 Grandview Ave. Pittsburgh, PA 15211 Notarial Seal Alison Brookas, Notary Public Pittsburgh, Alleghany County My Commission Expires Feb. 19, 2004 Mambar. PennsyiVanial\SSOClaliOllofNolarieS THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~~ ~~,~ ~ ' L" 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 Settle and Discontinue was served upon the following by United States First Class Mail, postage prepaid on this 20TH day of June, 2001: KAY L. SUCCA 1 ORRS BRIDGE ROAD CAMP HILL, PA 17011-1914 11/t/Jd f} hntDL Michelle D. Smitfi, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. l.""""l~ith;~<~,"~~ ~.IDl~I!Hr'~_~'ii1i!J/!!IijIlOjj~S,-,o(&"~;;>'.\:'_'l:"'@J~n,"'r,-'ii:*1^",,@-e-"dj.1Ye:<_J."'-be',," "&- f-/O "~ ~ ~~+ ,~ ""=. ~~, ,,- ~~"~ -,~,. ,"~ ,.-lM~'t"',"*I~,;<i:'}I1ir~""';'_')r!!'il0\<,?~~.~~~'-.. i.fu.....c:: J ~'.<..l_--~ '""^ " ~_~"_ I"" ,_ ,=w. ~-""_. .'". ," "'-'"'""..~" ~,~"","", ,~ ~-:' C) C--:J C;' c: .--;"] -rj :s::. ~~ rn r-'- :;:.: 1",) ,,<,Ti .- 0 ~ f'.J '~"'~~) ~ -,-~ "i-:: _:..~ X; c -..,~ , :~~(') ~ (:.-:' i;-? (~)ln '~ ~- c.=- -l :2: ~n 5'5 __I -< I" -< ~ ,';--"" , J. o~,~~""'-~. ~ ~"~ ~,__ ,1,.;,_ L...~~ <" J'_~~..&' SHERIFF'S RETURN - REGULAR CASE NO: 2001-03087 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS SUCCA KAY L STEVE WHISTLER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SUCCA KAY L the DEFENDANT , at 1235:00 HOURS, on the 7th day of June 2001 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQ CARLISLE, PA 17013 by handing to KAY L SUCCA 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 Mileage Affidavit Surcharge So Answers: 18.00 7.44 .00 10.00 .00 35.44 ~~~-t:~ R. Thomas Kline me this :I<. ~ day of ~ ~I A.D. 1.-. D /h-Jl/:--; ~ rothonotary 06/07/2001 MOLICA & MURRAY BY'~v0lk Deputy Sheriff Sworn and Subscribed to before