HomeMy WebLinkAbout07-1704IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY
Vs.
TRAVIS L. HURST
Plaintiff, CIVIL DIVISION
No. 07 - P70y
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 Aefenses 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
s; CARLISLE, PA 17013
717-249-3166 OR 800-990-9108
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
?3 BE USED FOR THAT PURPOSE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
t
BENEFICIAL CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
No. 0'7 .-Plaintiff,
vs.
TRAVIS L. HURST,
Defendant.
?r
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, TL 60070
TYPE OF PLEADING:
Complaint
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER
DISCOUNT COMPANY
Defendant's Address:
1262 HUNTERS RIDGE DRIVE
MECHANICSBURG, PA 17050
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
t
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
4t' Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
i
s
BENEFICIAL CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
Plaintiff,
No.
vs.
TRAVIS L. HURST,
Defendant.
COMPLAINT
AND NOW COMES, the Plaintiff, BENEFICIAL CONSUMER DISCOUNT
COMPANY, by its Attorneys, Chromulak & Associates, LLC, with its Civil Action
r
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
f
situated at 2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred to as "Plaintiff'.
2. TRAVIS L. HURST is an adult individual residing at 1262 HUNTERS RIDGE
DRIVE, MECHANICSBURG, PA 17050.
3. On! or about JANUARY 15, 2003, Defendant entered into a written Loan
Agreement with the Plaintiff, as evidenced by the Endorsed Check, 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.
F
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 14OVEMBER 26, 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 FOUR THOUSAND THREE HUNDRED
FORTY THREE AND 47/100 ($4,343.47) DOLLARS as of JANUARY 3, 2007.
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 the entire
b
indebtedness, including without limitation, principal, accrued interest, costs of collection and
reasonable attorney's fees.
WHEREFORE, Plaintiff claims damages in the sum of FOUR THOUSAND THREE
HUNDRED FORTY THREE AND 47/100 ($4,343.47) DOLLARS, with interest thereon at the
rate of 17% from JANUARY 3, 2007, plus court costs and attorney's fees.
Respectfully submitted,
Chromulak & Associates, LLC
By: /?..
CA HY ANN CHROMULAK, ESQ.
PA NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
KURT J. WINTER, ESQ.
PA ID NO. 84801
Attorneys for Plaintiff
375 Southpointe Boulevard
THIS IS AN ATTEMPT TO 4'' Floor
COLLECT A DEBT AND ANY Canonsburg, PA 15317
INFORMATION OBTAINED-WILL
BE USED FOR THAT PURPOSE.
Account Opener 018626
B@hE?1C1c11? 7 1 17 1 4-1 2020000PROS 170500000-5000F27.1994105030196265
LCANS
ACEYo"GN APFCRU
Sdcvrcl YOU CAN REty Ord
1>f1811111l11111111f1111?flnll?If11111Ell11101mill1IE11IN
Pay to the
nnle.of Travis L Hurst
FIVE THOUSAND AND 88/100
Not valid after: February 6, 2003
911714011162"10
AUTOCR SORT ** R 022
Travis L Hurst 012303
1262 Hunters Ridge Dr
Mechanicsburg, PA 17050-9183
I??.IIIr.rIII.... I.W1...Ill.../rllll?llllltllil,l,11111.r1,t
HOUSEHOLD BANK tsb.
70-7001
1301 E. Tower Road 2719
Schaumburg. IL 60173
December 30,, 2002
AMOUNT: S?UOO.O$
DOLLARS
TH15 15 A SULIGI IAI IVn rUm n Lulin - Rr1.u .1a,c
ENCLOSEDD? iZE5p?i DISCLOSURES BEFORE SIGNING AND
M Q.P eriicAa4ihe t 3346
terms of your loan agreement contained in Form Y27I99PA(12002)410.
If this oiler Is not accepted, please destroy this check
AUTHORIZED SIGNATURE
1100 19004040811' lee 2 7 19 700 1 11: 7`111`1401136261.00 11'0000 500088se
E EXHIBIT
'A p
(7 (717) 7A3-/i?v
(RUM" ?+ane PYane riuubff Work Pim Mr ben
812 P24
F R?3 -
I A BANK
0"1 / 1 4.003
9OO 4 C3- C1C33C3_ f i ..
CJ f 5- y.
03 1 121 1 159 03
? ? ..a
.7P I D-5
.4
. .
dpE W ?
? u? ?
?j '.. ! d
?'3 Cwt
Q1
.rL ? ? W ?
1 ?
- T. ,-IA a\ W
U
m
m
•.t :z" i.,
y??
Q?
ma? w
u s r
?
A Q
. fti; o
a
m
e
49 *
a
s s
E
E m
Z Z
oil
v
account Opener 000142 70--7001
711781-12020000PROS616140000-5000F27.1994104100001421 1361 E.To-rRoad
La+ Ycu Cw AFwa6. HIM Scheumb.,9. IL 66173 2719
0-= Ytal CA. R¢Y orc IIIIIM III IN 11111111111111111111111111111 December 30, 2002
Pay to th6
order of Sample A
FIVE THOUSAND AND 88/100
Not valid after: February 6, 2003
AMouNT: $3,000.88
DOLLARS
7117214OD142-410 s EN SED DISCLOSURES BEFORE SIGNING AND
G THIS CHECK
B np the Wek o/1Ms eMOk you cotes! our otter and spine S. the
Sample A Sample urban s0memeM coMdnad an Form trzTltrePA(12102)116- .,
123 Main Apt A It this onei Is not aaepbd, paaee dewy this chaca.
Anytowu, PA 61614
{?{{taus{{.{{nw{{t{n{n{.?{ ?` 7?/ -
AUTHORIZED SIGNATURE
1110 1 900 40 40811' 1: 2 7 19 70D 1 LI: 7 1 i 78 1DOD 14 2 Oil'
Bmd1r_ r
LMM You Ci ANOM
SOWCE NOV CM Rn.Y Olt
Customer ED No.: 410 4100001421
Check Amount: 55,000.88
Ste 10 ?
6000 North Broad Street A special congratulations from Beneficial
Philadelphia, PA 19141 and your check for $5,000.88 I 1
Dear Sample A Sample, ?
Congratulations. Attached is a check for $5,000.88 to open your loan account. Please be sure to sign the back
before you cash it or deposit it in your bank account.
? Use your Beneficial loan any way you want.
Use the $5,000.88 from Beneficial for anything you'd like. Make that special purchase. Pay a few bills. Enjoy a
relaxing getaway or fix-up the car or your house. With this Beneficial loan, the choice is entirely up to you.
i
In addition, your loan payments are designed not to strain your budget. Take up to 60 months to repay your loan
and pay as little as $153.30 a month.* Or, if you prefer, you can make larger payments when you're able to.
If you have any questions, call the Beneficial Loan Education Center at 1-866-396-INFO (4636).
We want you to get the most out of this opportunity. But we also want you to understand the terms and
conditions of this loan offer. So if you have any questions about your an or to learn more about Beneficial,
please call the Beneficial Loan Education Center at 1-866-396-INF014636) Monday through Friday from
9 a.m. to 11 p.m. EST, and Saturday from 9 a.m. to 3 p.m. EST. You'll find that real answers are just a phone
call away.
Please visit our branch office for any reason.
If you'd like more money, we're always here to help with friendly service and affordable financing solutions.
Beneficial will work with you to find the loan and repayment terms that fit your needs. Please stop by or call our
branch office:
Ste 10, 6000 North Broad Street, Philadelphia
(215) 224-1743
We think you'll be pleased with the Beneficial commitment to service, and above all, our commitment to you.
But that's not surprising, because for over 85 years, Beneficial has been providing flexible financing to
responsible families. Now you can be part of that tradition. We look forward to working with you.
Sincerely,
Rena Williams-Taylor
Branch Manager, Beneficial
P.S. To accept this loan offer, please be sure to sign and deposit your check before February 6, 2003.
If you do not accept this loan offer, please remember to destroy the attached check.
• Based on a loan term of 60 months, with an Annual Percentage Rate of 27.199%. The Promissory Note and Disclosures found on the back contain a
full explanation of the terms and conditions of your loan.
SPECIAL NOTICE - Please sae the enclosed docomenb entitled "Important Notice Required Under The Fair Credit Reporting Act" and
"Privacy Statement" for important information on your rights.
If you do not wish to receive any further solicitation, please call (215) 224-1743.
27199PA(12102)4r0
8497xx6 m7° ato
0006 G9 ? An Equal Opportunity Lender HCM9
Y.'.'.. 1CP-('HC K41I3
if
I 1 t ?
(Rap4aw, nmo Phoe Nwobw Wak Ph- Nmea
z ? s "-
?g ?E
25
W of
q o m
i
PROMISSORY NOTE AND DISCLOSURES
CREDITOR (Called "We", "Us", "Our): BORROWER (Called "You", "Your'):
Beneficial Consumer Discount Company Sample A Sample
Ste 10 123 Main Apt A
6000 North Broad Street ? Anylrwm, PA 61614
Philadelphia, PA 19141
• ANNUAL PERCENTAGE HARAF
• FINAN Amount Financed Total of Payments Date
?? .
The dollar amount the credit The amount of credit The amount you will here of
The cost of your credit as e will cost you.
? provided to you or on
your behalf. ? paid after you have made all
payments as scheduled. Loan
tell yearly rate. 27.1997E
$4,197.12 •e•
$5,009.68
E9,196.00 •e•
December 30, 2002 •e•
Your Payment schedule will be:
Are tills:
When
Payments
the Fin
Finance
Charge.
a refund of part of
Lek Charge: t you don't pay any payment In 10 days ~ Ks due. your was else pay 1-112% per wadh an the amonnd overdue (su*d in a
S1.9D mhdmum charge).
See below for any additional information about nonpayment default, any required repayment In fed before the scheduled date, and prepayment refunds and penalties.
•a• means an estimate
PROMISE TO PAY. By signing the attached check, you agree to the terms of this Promissory Note and Disclosure and promise to pay us the Total of Payments low sum of
Finance Charge plus the Amount Financed) in monthly payments as stated above. Finance Charge Includes a nonrefundable tea or $150 red interest whisk has been calculated
in advance at the Contract Rate of 25.698 per year on the scheduled unpaid balances on the assumptions the payments are made on
DATE ON WHICH FINANCE CHARGES BEGIN. PAYMENT DATES. This ban will be consummated on the date you cash the check for the loan proceeds which you received
with this Promissory Note and Disclosures. Finance Charges will begin on the date the chock Is cashed.
PREPAYMENT. If you fully pay before the fmal payment due date, the amount you owe will be reduced by umeemed Finance Charges (but not the Service charge) determined
by the Rule of 78ths.
LATE CHARGE. If you don't pay any payment In 10 days after Ira due, you will also pay 1-112% par month on the amount overdue (subject to a $1.01) minimum charge).
BAD CHECK CHARGE. We will charge you a fee of $20 It 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 (a) all your payments may become due at once and without notltyleg you before bringing suit, we may sue for the total
amount you owe Ins any unearned Finance Charges you would receive lf you fury prepaid, and (b) you will also pay our reasonable attorney fan, If the attorney is not our
salaried empbyee, for legal proceedings to collect this ban or realize on security.
ALTERNATIVE DISPUTE RESOLUTION. Terms of the Arbitration Provision is provided with this Promissory Note and Disclosure is Incorporated heroin by reference.
CREDIT REPORTING AND CUSTOMER INFORMATION PRACTICES. t you fat to UN the terms of your credit obligation, a negative report reMcting on your craft record
may be submitted to a Credit Reporting Agency. You agree that the Deportriond of Motor Vehicles (or your state's equivalent of main department) may release your residence
address to us, should it become necessary b book you. You agree that our supervisory personnel may listen to telephone cats between you and our representatives in
order to evaluate the quatly of our comics to you. For more information regarding our privacy practices, please refer to the enclosed Privacy Statement.
ITEMIZATION OF AMOUNT FINANCED. The entire Amount Financed (shown above) will be given directly to you.
Payments
Number
of Amount
of
Payments
60 ? $153.30
? Monthly, beginning on the Payment Due Dale shown on the fast Bitting
Statement.
unused to
elf poly, you may
be
If you pay
Prepayment
000112?A-471410101
?
z71esPA(12102)410
?
PAPGCNLB
PAD1Se.Or
09190102 71:90 AY
i
VERIFICATION
D I AN NA WIGGINS $ Recover Specialist for
Bli''VEFICIAL CO NSUI R DISCOUNT CCU". MIY
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-
r
1
DIANNA WIGGINS
ru
M J
r .- l
I O&Z
r A &
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
Plaintiff,
CIVIL DIVISION
No. 07-1704 CIVIL TERM
vs.
TRAVIS L. HURST,
Defendant.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
1262 HUNTERS RIDGE DRIVE
MECHANICSBURG, PA 17050
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
TYPE OF PLEADING:
Praecipe to Reinstate 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
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4'' Floor
Canonsburg, PA 15317
(724) 916-2400
r?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
Plaintiff,
No. 07-1704 CIVIL TERM
vs.
TRAVIS L. HURST,
r
Defendant.
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the complaint in the above-captioned action, at 07-1704 CIVIL TERM
and mark the docket accordingly.
BY (1??
CATHY ANN CHROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
Y
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4'h Floor
Canonsburg, PA 15317
(724) 916-2400
s
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
N
CAJ
. 4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 07-1704 - CIVIL TERM
Plaintiff,
TYPE OF PLEADING:
vs.
Praecipe for Default Judgment
TRAVIS L. HURST,
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER
DISCOUNT COMPANY
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant.
Defendant's Address:
1262 HUNTERS RIDGE DRIVE
MECHANICSBURG, PA 17050
Dated: MAY 29, 2007
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND
ANY INFORMATION
OBTAINED WILL BE USED
FOR THAT PURPOSE.
COUNSEL OF RECORD:
CATHY ANN CHROMULAK? ESQUIRE
PA ID NO. 42067
MAUREEN A. DOWD, ESQUIRE
PA ID NO. 90549
BETH ARNOLD HOWELL, ESQUIRE
PA ID NO. 203606
CHRISTINE A. SAUNDERS, SQUIRE
PA ID NO. 203373
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4'h Floor
Canonsburg, PA 15317
(724) 916-2400
TO: PROTHONOTARY
Please enter judgment by default against the within-named defendant, TRAVIS L.
HURST, for failure to file an Answer as follows:
Amount Claimed in Complaint: $4,343.47
Interest from 1/04/07 through 5/29/07: 301.86
Costs of Collection through 5/29/07: 585.58
TOTAL $5,230.91
With interest accruing on the total balance of $5,230.91 at the rate of 6% per ann , together
with additional costs of suit.
BY
CATHY ANN CHROMULAK, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
BETH ARNOLD HOWELL, ESQUIRE
CHRISTINE A. SAUNDERS, ESQUIRE
Attorneys for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATION OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF WASHINGTON
SS:
Before me, the undersigned authority, a Notary Public in and for said County and State,
personally appeared, Qmoj , ESQUIRE, attorney for and
authorized representative of plaintiff who, being duly sworn according to law, dep ses d says
that the defendant is not in the military service of the United States of America to t e bes?t of her
knowledge, information and belief and certifies that the Notice of Intent to take Default
Judgment was mailed to defendant on MAY 15, 2007 by certificate of mailing i accordance
with Pa.R.C.P. 237.1, as evidenced by the attached copy.
CATHY ANN CHROMULAK, ESQUIRE
MAUREEN A. DO SQUIRE
BETH ARNOLD HOWELL, E QUIRE
CHRISTINE A. SAUNDERS, SQUIRE
Sworn to and subscribed before me
This 24k- day of , 2007.
Notary Public
::OMMONWEALTH OF PENNSYLVANIh
Notarial Seal
leather L Hatfield, Notary Public
Cecil Twp., Washington County pp
My Commission Expires June 29, 2010 E
Alsrrmh p-a.^,nsy!vs nip '?9so&,fior, of Notariek.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND
ANY INFORMATION
OBTAINED WILL BE USED
FOR THAT P RPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
Vs.
TRAVIS. L. HURST,
Plaintiff,
Defendant(s).
TO: TRAVIS. L. HURST
1262 HUNTERS RIDGE DRIVE
MECHANICSBURG, PA 17050
DATE OF NOTICE: MAY 15, 2007
IMPORTANT NOTICE
No. 07-1704
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITE,
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FOF
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF TB
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARD
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU S.
THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OF]
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.
By:
VANIA
TERM
A WRITTEN
G WITH THE
H AGAINST
S NOTICE, A
G AND YOU
OULD TAKE
AWYER OR
'ICE TO FIND
CATHY ANN CHROMULA , ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, SQ.
CHRISTINE A. SAUNDERS, SQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4'h Floor
Canonsburg, PA 15317
fL ?.
W
! SO CD Ut
• ! J Q Z y l?y.??1j
t ca 3 /y
OR =
gc 11 G
3 wg ?
Ln in u,
N G C> o z VI A,
V+ AA qW0 O O u
c, :5
x y b O N n n uj N Z S C5? I,C?
a r cxd n Rg a ; p
g r
tij
n r r
I'M
r
pO d0
?• ? 9 9 ? o
$? G ?rC p i y
~ k I Y?
W
j o I `? o
t S 3
;a
10 `
106
lw - D4
16
wit
c° o
6
3 .,:u )w
? ,.V r,/C.C4 7}
??55 ? ?^?? UNt7'FCy
S
0- six
• $' ~ I.,S1 1.J"t Lbw
t%
I&W 1
MUFF
?? ?
`?--- ? - d
? w ?' ?
??
-a?
?'-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 07-1704 - CIVIL TERM
Plaintiff,
VS.
TRAVIS L. HURST,
Defendant.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: TRAVIS L. HURST
1262 HUNTERS RIDGE DRIVE
MECHANICSBURG, PA 17050
I,
(X) Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above
captioned proceeding on _ (= 2(XQ!
O A copy of the Order or Decree is enclosed, or
(X) The judgment is as follows: $5,230.91 plus interest at the rate of 6% per
annum and additional costs of suit.
THIS IS AN ATT EMPT TO
COLLECT A D ST AND
ANY INFOR ATION
OBTAINED WIL BE USED
FOR THAT PU POSE.
N_ O
-n
-
i
t'YI
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2007-01704 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
HURST TRAVIS L
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
--- - - b t
unable to locate Him in his bailiwick.
/t/lnnnT T TTTT r TTn Ir T/=
LA was
He therefore returns the
the within named DEFENDANT
1262 HUNTERS RIDGE DRIVE
HURST TRAVIS L
NOT FOUND , as to
MECHANICSBURG, PA 17050
PER POST OFFICE, DEFENDANT MOVED AND
LEFT NO FORWARDING ADDRESS.
Sheriff's Costs: So answer
Docketing 18.00 r°
Service 9.60
Not Found 5.00 R. Tho as Kline
Surcharge 10.00 Sheriff of Cumberland County
.00
42.60 CHROMULAK & ASSOCIATES
04/05/2007
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-01704 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
HURST TRAVIS L
MICHAEL BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
HURST TRAVIS L the
DEFENDANT
at RED LOBSTER
at 1948:00 HOURS, on the 24th day of April 2007
4711 CARLISLE PIKE
MECHANICSBURG, PA 17050
TRAVIS HURST
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 12.48
Affidavit .00
Surcharge 10.00
.00
61;1/61 40.48
Sworn and Subscibed to
before me this day
of
So Answers:
R. Thomas Kline
04/26/2007
CHROMULAK & ASSO ATES
By. 1 4 - - -
ut herif A.D.
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
TRAVIS L. HURST,
lea I+u?jn*As P.?d%L Orwe Defendant,
Meth, Pa 17090
COMMERCE BANK,
105 Ashland Ave
Cad s(L, PA 17013 Garnishee.
CIVIL DIVISION
No. 07-1704-CIVIL TERM
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 TRAVIS L. HURST, defendant, and
3. against COMMERCE BANK, garnishee,
4. and index this writ
a. against TRAVIS L. HURST, defendant, and
b. against COMMERCE BANK, garnishee, and any property of the defendant in the
name of Garnishee:
Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual and
joint, personal and business.
5. Amount of Judgment
Additional Interest to Date
(Costs to be added)
$5,230.91
$ 65.25
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.
$5,296.16
ATHY CHROMt AK, ESQ.
MAUREEN A. DOWD, ESQ.
CHRISTn?l?A. SAUNDERS, ESQ.
BETH ARNOLD HOWELL, ESQ.
-6? C'? ° C-n7
FD
o O
O
-
=
o
.r-
0 r
7 6--
X000000
toc,
Vr p
I;p 1?
rl>
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-1704 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 TRAVIS L. HURST, 1262 HUNTERS RIDGE DRIVE, MECHANICSBURG, PA 17050
(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
GARNISHEE(S) as follows:
COMMERCE BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013
ALL MONIES DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL
AND BUSINESS.
and to notify the gamishee(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 $5,230.91
L.L. $.50
Interest to Date - $65.25
Atty's Comm %
Atty Paid $212.58
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 8/17/07
(Seal)
REQUESTING PARTY:
Name BETH ARNOLD HOWELL, ESQUIRE
C is R. Long, Prothonolgry
By:
Deputy Address: CHROMULAK & ASSOCIATES, LLC
375 SOUTHPOINTE BLVD., 4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203606
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-01704 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
HURST TRAVIS L
And now RICHARD SMITH
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0008:35 Hours, on the 23rd day of August , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
HURST TRAVIS L
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE M ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
LINDA AUL (TELLER
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscribed to
before me this
, in the
true
and made
So answers:
.00
.00 4?
.00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00
. 0 0
08/23/2007
day of By
Deputy Sherif
A.D
1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY,
Plaintiff,
CIVIL DIVISION
No. 07-1704-CIVIL TERM
vs.
TRAVIS L. HURST,
1262 HUNTERS RIDGE DRIVE
MECHANICSBURG, PA 17050
Defendant,
and
COMMERCE BANK
Garnishee.
TO: COMMERCE BANK
65 ASHLAND AVE.
CARLISLE, PA 17013
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.
AA.3TCZea qo 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:
No
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:
No
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
T URD: 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:
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 (or in which Defendant)
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 a fiduciary
any property in which the Defendant had any interest?
RESPONSE:
No
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:
No
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:
No
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:
No
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:
No
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
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:
No
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:
No
DATE: dt?-R
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By: Tx!f6,-?dua
Cathy Ann Chromulak, Esq.
Maureen A. Dowd, Esq.
Christine A. Saunders, Esq.
Beth Arnold Howell, Esq.
375 Southpointe Boulevard
4'' Floor
Canonsburg, PA 15317
(724) 916-2400
Commerce Bank
3801 Paxton Street
larri burg, PA 17111
J7. 412-6134
Date
r-3
t:o
3N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
vs.
TRAVIS L. HURST,
and
COMMERCE BANK,
Plaintiff,
CIVIL DIVISION:
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant,
Garnishee.
Defendant's Address:
14 GREY PLACE
MECHANICSBURG, PA 17055
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
No. 07-1704-CIVIL TERM
TYPE OF PLEADING:
Praecipe to Discontinue
Against Garnishee 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
4N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
VS.
TRAVIS L. HURST,
and
COMMERCE BANK,
Plaintiff,
Defendant,
Garnishee.
CIVIL DIVISION:
No. 07-1704-CIVIL TERM
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO THE PROTHONOTARY:
Please discontinue this action against the above garnishee, COMMERCE BANK, and
mark the docket accordingly.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By: Plek'Jimlea
CATHY ANN CHROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
Sworn to and subscribed
Before me this _
day
11 LI
of , 2007.
44/
NotarPublic
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
oeamar c :yatiinlo. + {otary Public
i Cecil +Vastj n"$On COUrriy
L My Come emission Expires June 29, 2010
"?+^"? . Pe^rayfvania Assoclatic n of Notaries
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 Discontinue Against Garnishee Only was served
upon the following by First Class Mail, postage prepaid on this 11TH day of October, 2007.
COMMERCE BANK
3801 PAXTON STREET
HARRISBURG, PA 17111
TRAVIS L. HURST
14 GREY PLACE
MECHANICSBURG, PA 17055
T)R? ?Ia
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.
C N
cq-
4 90
r -1
Un
I T1
_. c.n
J
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .?
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
VS.
TRAVIS L. HURST,
and
INTEGRITY BANK,
Plaintiff"s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Plaintiff,
Defendant,
Garnishee.
Defendant's Address:
14 GREY PLACE
MECHANICSBURG, PA 17055
Garnishee's Address:
3345 MARKET STREET
CAMP HILL, PA 17011
Date: January 18, 2008
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CIVIL DIVISION
No. 07-1704 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
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
TERESA K. GABRIEL, ESQ.
PA ID NO. 205696
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
f ?
IN THE COURT-OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
VS.
TRAVIS L. HURST,
and
INTEGRITY BANK,
TO: The Prothonotary
Plaintiff,
Defendant,
Garnishee.
CIVIL DIVISION
No. 07-1704 CIVIL TERM
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 TRAVIS L. HURST, defendant, and
3. against INTEGRITY BANK, garnishee,
4. and index this writ
a. against TRAVIS L. HURST, defendant, and
b. against INTEGRITY BANK, garnishee, and any property of the defendant in the
name of Garnishee:
Said Writ of Execution is pursuant to all monies due defendant in any accounts individual and
Joint, personal and business.
5. Amount of Judgment
Additional Interest to Date
(Costs to be added)
Minus Payments
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.
$5,230.91
$265.48
$ 530.00
$4,966.39
CATHY ANN C OMULAK, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
BETH ARNOLD HOWELL, ESQ.
TERESA K. GABRIEL, ESQ.
04
00
# w
v,oID
?o?0 o v
a
OD (> 0
O ? O 'b r= s v T'?.3 {t
3 00
7
t?J
C
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-1704 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 TRAVIS L. HURST, 14 Grey Place, Mechanicsburg, PA 17055
(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
GARNISHEE(S) as follows:
INTEGRITY BANK, 3345 Market Street, Camp Hill, PA 17011
Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual and joint,
personal and business.
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 $4,700.91
Interest -- $265.48
Atty's Comm %
Atty Paid $242.58
Plaintiff Paid
Date: 1/22/08
L.L.
Due Prothy $2.00
Other Costs
X 14 k?
Curtis ong, P onot
(Seal)
REQUESTING PARTY:
Name CHRISTINE A. SAUNDERS, ESQUIRE
Address: CHROMULAK & ASSOCIATES, LLC
375 SOUTHPOINTE BOULEVARD, 4TH FLR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
By:
Deputy
Supreme Court ID No. 203373
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-01704 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
HURST TRAVIS L
And now STEVE BENDER Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0013:50 Hours, on the 4th day of February-, 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
HURST TRAVIS L , in the
hands, possession, or control of the within named Garnishee
INTEGRITY BANK 3345 MARKET ST
CAMP HILL, PA 17011
Cumberland County, Pennsylvania, by handing to
TRISH PLACIDO (CUSTOMER SERVICE REP) ,
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 answers:
Docketing .00 f
Service .00
} ~ b !=_.e..?
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
? ?107??
00
02/05/2008
Sworn and Subscribed to
before me this day of By
Deputy Sheriff
A.D
l
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY,
Plaintiff,
VS.
TRAVIS L. HURST,
Plaintiffs Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant.
CIVIL DIVISION:
No. 07-1704 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
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
TERESA K. GABRIEL, ESQ.
PA ID NO. 205696
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4t` 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.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY,
Plaintiff,
vs.
TRAVIS L. HURST,
Defendant.
CIVIL DIVISION:
No. 07-1704 CIVIL TERM
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Please satisfy the judgment against TRAVIS L. HURST, at No. 07-1704 CIVIL TERM,
and mark the docket accordingly.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By: 0 p -Q-1a r • a 2LQ
CATHY ANN CHROMULAK, ESQ.
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
TERESA K. GABRIEL, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4t" Floor
Canonsburg, PA 15317
Sworn to and subscribed
Before this `G*I- day
of r , 2008.
Notary Polic
OMMONWEALTH OF PENNSYLVAM
Notarial Seal
Heather L. Hatfield, Notary Public
Cecil Twp., Washington County
My Commission Expires June 25, 2010
;vas^?:1 15?nCl a+ =:?;
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 15TH day of FEBRUARY, 2008.
TRAVIS L. HURST
14 GREY PLACE
MECHANICSBURG, PA 17055
Cathy Ann Chromulak, Esq.
Beth Arnold Howell, Esq.
Christine A. Saunders, Esq.
Teresa K. Gabriel, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
??
:??
"LlE-.? ? T?.
r
-? _-??
? ??
_..- :•?
??
? . s`^=
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
Plaintiff, No. 07-1704 CIVIL TERM
VS.
TYPE OF PLEADING:
TRAVIS L. HURST, Praecipe to Discontinue
Against Garnishee ONLY
Defendant,
AND TYPE OF CASE:
INTEGRITY BANK, Civil Action
Garnishee.
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
Plaintiff's Address: COMPANY
2700 Sanders Road
Prospect Heights, IL 60070
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
TERESA K. GABRIEL, ESQ.
PA ID NO. 205606
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th 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.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
Vs.
TRAVIS L. HURST,
and
INTEGRITY BANK,
Plaintiff,
Defendant,
Garnishee.
CIVIL DIVISION
No. 07-1704 CIVIL TERM
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
Please discontinue this action against the above garnishee, INTEGRITY BANK and mark
the docket accordingly.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
6" e/
CATHY ANN CHROM AK, ESQUIRE
BETH ARNOLD HOWELL, ESQUIRE
CHRISTINE A. SAUNDERS, ESQUIRE
TERESA K. GABRIEL, ESQUIRE
Attorneys for Plaintiff
375 Southpointe Boulevard
4t' Floor
Canonsburg, PA 15317
Sworn to and subscribed
Before me this H-1'7- day
of '2008.
Notary P blic MMONWEALTH OP PENNSYLVANV-
Notarial Seal
Heather L Hatfield, Notary Public
! Cecil Twp., Washington County
My Commission Expires June 29, 2010
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
"mher, P mnsvlvania Association of Notari ,
I..
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 Garnishee Only was served
16
upon the following by First Class Mail, postage prepaid on this h day of February, 2008.
BECKY BACHER
INTEGRITY BANK
3345 MARKET ST.
CAMP HILL, PA 17011
TRAVIS L. HURST
14 GREY PLACE
MECHANICSBURG, PA 17055
?ii
M(?/
Cathy Ann Chromul , Esq.
Beth Arnold Howell, Esq.
Christine A. Saunders, Esq.
Teresa K. Gabriel, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
r~' C?
C>
?
4f ? i ..?y ?€1
`
'Ile
3
a
r
G
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: Advance Costs: 150.00
Sheriff's Costs 86.19
Docketing 18.00 63.81
Poundage 1.69
Advertising
Law Library .50
Prothonotary 2.00 Refunded on 05/07/08
Mileage 5.00
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.00
TOTAL 86.19 ? 51So Answer
L
R. Thomas Kline, Sheriff o
rya e,+
By
c:_ 7
?, ,2v894a
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-1704 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 TRAVIS L. HURST,1262 HUNTERS RIDGE DRIVE, MECHANICSBURG, PA 17050
(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
GARNISHEE(S) as follows:
COMMERCE BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013
ALL MONIES DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL
AND BUSINESS.
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 $5,230.91
L.L. $.50
Interest to Date - $65.25
Atty's Comm %
Atty Paid $212.58
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 8/17/07
(Seal)
REQUESTING PARTY:
Name BETH ARNOLD HOWELL, ESQUIRE
Lsl e- i...
Ctirtis R. Long, Prothono
By: L 64 , An4v
Deputy
Address: CHROMULAK & ASSOCIATES, LLC
375 SOUTHPOINTE BLVD., 4'H FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203606
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriffs Costs:
Docketing 18.00
Poundage 1.85
Advertising
Law Library
Prothonotary 2.00
Mileage 13.44
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.00
?I13?b g
9
TOTAL ?
94.2
Advance Costs: 150.00
Sheriff's Costs 94.29
55.71
Refunded on 05/07/08
ti
So Answers,
R. Thomas Kline, ens
By
LS :b e sZ Ndr Boot
tld'A1Nf100 uNViH38Wj31
AA183HS 3H1 J0 301. 30
1d.`sa
0
a
1dpg?j6
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-1704 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 TRAVIS L. HURST, 14 Grey Place, Mechanicsburg, PA 17055
(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
GARNISHEE(S) as follows:
INTEGRITY BANK, 3345 Market Street, Camp Hill, PA 17011
Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual and joint,
personal and business.
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 $4,700.91
Interest -- $265.48
Atty's Comm %
Arty Paid $242.58
Plaintiff Paid
Date: 1/22/08
(Seal)
L.L.
Due Prothy $2.00
Other Costs
Curtis . Long, Pr o
By:
REQUESTING PARTY:
Name CHRISTINE A. SAUNDERS, ESQUIRE
Address: CHROMULAK & ASSOCIATES, LLC
375 SOUTHPOINTE BOULEVARD, 4TH FLR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Deputy
Supreme Court ID No. 203373