HomeMy WebLinkAbout01-06622
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
RICHARD B. BUCHER,
Defendant.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
37 N. Baltimore Avenue
Mt. Holly Springs, PA 17007
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
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CIVIL DIVISION
Ciou. T~
No.OI - ~(..~~
TYPE OF PLEADING:
Complaint
TYPE OF CASE:
civil Action
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 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211"1205
(412) 381-7000
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
Clo\l'-r~
No. 0 t - ~ I-:u......
Plaintiff,
vs.
RICHARD B. BUCHER,
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 OEBT ANO ANY INFORMATION
OBTAINEO WILL BE USEO FOR
THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 01 - l...{,~^-- Q-IO~ L ~~~
Plaintiff,
vs.
RICHARD B. BUCHER,
Defendant.
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. RICHARD B. BUCHER is an adult individual residing at
37 N. Baltimore Avenue, Mt. Holly Springs, PA 17007.
3. On or about August 10, 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.
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
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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 May 31, 2001.
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 Thirteen Thousand Four
Hundred Forty Five and 33/100 ($13,445.33) Dollars as of October 5,
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
Thirteen Thousand Four Hundred Forty Five and 33/100 ($13,445.33)
Dollars, with interest thereon at the rate of 21.991% from October
5, 2001, plus court costs and attorneys' fees.
Respectfully submitted,
MOLLICA & MURRAY
By:
f7JlA(/ /J l1nr:2-
CATgy 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 OEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
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LOAN REPAYMENT AND SECURITY AGREEMENT (Page I of 2)
CREDITOR (called "We," "Us," "Our")
HOUSEHOLO FINANCE CONSUMER DISCOUNT COMPANY
;;
25 GATEWAY DRIVE
GATEWAY SQUAREISUITE 101
MECHANICSBURG PA 11055
BORROWERS (called "You," "Your")
BUCHER. RICHARD 8
SS# 209641759
31 N BALTIMORE AVE.
BOILING SPRGS PA 11007
LOAN NO: 113303-983189.
'\
GATE OF IoGA!;EMENT
lIF'E' 'D1SAan..lTY:
. 261.52 . 4Bl.21
MCIfTl-ILY INSTAllMENT f".UMENTlt
fIRST, oTHERS; (E"g.p1 a.noon)
318.48 318.48
NONE
YOU ARE GIVING US 'A SECURITY INTEREST IN THE REAL' ESTATE LOCATED AT THE ABOVE ADDRESS.
REQUIRED INSURANCE. Ynu must obtain wurance for term of loan cover-ing sflcurit'y for lhi!i loan liS indicated. by the word "YES"
below. 'nami..ng liS as Loss Poyee:
Title insurance on real cstato security', \\ \
F. d d' ed \\ ,~,~~. "I.. ~\ 'I' .
1:(e an extco covera~.lnsurance Qil,tea estate securtty.
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Physical damage insurance 011 .motOr rehicle muked "Insured':' under "Security" above.
Physical damage insurance on other property mal'ked "Insured" under "Sec:urityll 'above.
Y O\l may obtaio. any required i:osurancer from anyone you choose.
YEs
NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS.
09-19-97 LIS PA C.E.
1ST MORT.
PAOB5911
ORIGINAL.
EXHIBIT
A
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LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 2)
PAYMENT. In return f<>r your loan described below, you shall pay us the Amount Financed including the Fee (all shown
on page onel plus Interest, in monthly payments, including any final Balloon Payment, as stated on page one. You may
pay more at any time. You will pay at our business address Or other address given you, If more than one Borrower is
named on page one, !ve may enforce this Agreement against all, or any, Borrowers, but not in.a combined amount greater
than the amount o"~d. Each payment will be first applied to Finance Charges at the Contract Rate shown on page one for
the actual time unpaid and the remainder to your unpaid Principal. For purposes <;>f computing Finance Charges, a month
shall be considered aAy period of 30 consecutive days,
I
DATE ON WHICH;FlNANc;E CHARGE BEGINS. If you do not cancel this loan according to your 'Notice 01 Right to
Rescind," the date on which Finance Charge begins, payment date, and effective date of optional insurance purchased in
conllection with this ioan are postponed by the number of days from this Agreement's date to date you receive this loan.
PAY-oUTS. You agJee to pay-outs of Amount Pinanced as shown on the Truth [n Lending disclosure form. If pay-out.
change because loan ~losing is delayed, (a) you will pay additional amounts due at closing, or (b) your cash or check will be
reduced to cover additional pay-outs. '
PREPAYMENT. Yo~ may prepay any or all of your loan at any time. If you fully pay ~fore tlfe final payment"due date,
. the amount you owe kill be reduced by unearned credit insurance charges.
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BAP CHECK CHARGE. We will charge YOll a handling fee of $20 if an'y payment check is returned because you had 00
account or for insuffihient funds.' . .
DEl'AULT. Subject ~o applicable law and the mortgage on YOllr real estate securing this loan, if you d~n't pay on time or
rail to keep required insurance in force, or if you sell or transfer all or any part of that real estate or any interest therein
without our consent, 'all your payments may become due at once. We will notify you of your right to correct such default
before we enforce th~ real estate mortgage, We m.ay sue you for the total amount you owe, and you will also 'pay our
reasonable attorney fJes (if the attorney is not our salaried employee), court costs, and fees incurred to collect this loan.
. I . ,
EXCHANGE OF INFORMATION. You understand that from time to time we may receive credit information
concerning you froml others,such os stores, other lenders, and credit reporting agencies. You authorize us to sbare any
information, on a rdgular basis, we obtain rel~ted 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 inciude an inquiry to determine if you qualify for additional offers of credit. You also authorize us to
share any iillormatio~ regarding your Account with any of our affiliated corporations, subsidiaries or other third parties.
After September 29, 1997, you may prohibi1 the sharing of such information (except for the sharing of
information aboutl1ransactions or cIperiences between us and you) ~y sending a written request which
contains your full name, Social Securi1Y Number and Address to us at P_O. Box 8602, Elmhurst, IL 60126.
If you fail to fulfilllthe terms of your ~Tedit obligation, a negative report reflecting on your credit record ma)' be
submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent
01 such department) bay release your residence address to us, should it become necessary to locate you. You agree that
our supervisory persbnnel may listen to telephone calls between you and oUr represen1atives in order to evaluate the
quality of our service: to you. .
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YOU HAVE RECEIVED A COMPLETED COpy
OF TillS AGREEMENT AND THE TRUTH-IN"LENDING
DISCLOSURES.
Ba]~~_
WITN ~
(SEAL)
(SEAL)
(SEAL)
09-29"97 liS PA C.E.
, ST MORT.
PAC55912
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ORIGINAL
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VERIFICATION
Merrilee Mastrangelo, Recovery Specialist for
HOUSEHOLD FINANCE 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.
astrangelo
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WIll. BE USED FOR
THAT PURPOSE.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001"06622 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
BUCHER RICHARD B
CPL. 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
BUCHER RICHARD B
the
DEFENDANT
at 1244:00 HOURS, on the 30th day of November, 2001
at 37 N BALTIMORE AVE
MT HOLLY SPRINGS, PA 17065
by handing to
RICHARD B. BUCHER
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
So Answers:
18.00
3.90
.00
10.00
.00
31.90
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R. Thomas Kline
12/03/2001
MOLLICA & MURRAY
y Sheriff
Sworn and Subscribed to before By:
tv
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day of
me this
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othonotary .
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
RICHARD B. BUCHER,
Defendant.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's address:
37 North Baltimore Avenue
Mt. Holly Springs, PA 17007
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CIVIL DIVISION
"t..~d-...,
No. 01-~ Civil Term
TYPE OF PLEADING:
Praecipe for
Default Judgment
TYPE OF CASE:
CIVIL ACTION
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 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.
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TO: PROTHONOTARY
Please enter judgment by default against the within"named
defendant, RICHARD B. BUCHER, for failure to file an Answer as
follows:
Interest from 10/6/01 thru 1/03/02:
$13,445.33
606.99
Amount claimed in Complaint:
Costs of Collection thru 1/03/02:
554.50
TOTAL
$14.606.82
With interest accruing on the total balance of $14.606.82 at the
rate of 6% per annum, together with additional costs of suit.
By: ;pJgpi/iJ orn,/-t
CATH 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 DEF~ULT 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 December 21. 2001 by certificate of
mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the
attached copy.
'lll~/l fin YL
CATHY ANN CHROMULAK, ESQ.
MICHELLE D. SMITH, ESQ.
Sworn to and sub~bed before me
this 7011 day of' r..a~-.y 2002.
~ _ _a_....h-... _~. a.... ~
tary Public
a
-
Notarial Seal
Yvonne Gardner Jones. Notary Public
Pillsbu'llh, Allegheny County
My Commission Expires Jan. 29, 2005
Member, Pennsylvania Association of Notari
HIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
Plaintiff,
~~^
No. 01~-CIVIL
vs.
RICHARD B. BUCHER,
Defendant.
TO: RICHARD B. BUCHER
37 N. Baltimore Avenue
Mt. Holly Springs, PA 17001
DATE OF NOTICE: December 21, 2001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHINcTEN 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 Avenu~
Carlisle, PA 17013
717"249-3166; 800-990"9108
By:
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CAT Y . CHROMULAK, ESQ.
MICHELLE D. SMITH, ESQ.
Attorrleys for Plaintiff
THIS IS AN ATTEMPT TO COllECT
A DEBT AND ANY INFORMATION
OBTAINED Will BE USED FOR
THAT PURPOSE.
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SHERIFF'S RETURN" GARNISHEE
CASE NO: 2001-06622 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
BUCHER RICHARD B
And now DOUGLAS DONS EN
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:29 Hours, on the 21st day of February, 2002, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
BUCHER RICHARD B
, in the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
WINI QUESENBERRY (BRANCH MANAGER)
personally three copies of interogatories together with 3
true
and attested copies of the within COMPLAINT & NOTICE
and made
the contents there of known to Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
.00
.00
.00
.00
.00
.00
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R. Thomas Kline
Sheriff of Cumberland County
day
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Deputy Sheriff
By
Sworn and subscribed to before me
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
No. Ol-6622
Plaintiff,
vs.
TYPE OF PLEADING:
PRAECIPE FOR A
WRIT OF EXECUTION
RICHARD B. BUCHER,
FILED ON BEHALF OF:
Defendant,
and
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COMMERCE BANK,
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MICHELLE D. SMITH, ESQ.
PA ID NO. 74800
Garnishee.
MOLLICA & MURRAY
Firm No. 952
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
l305 Grandview Avenue
450 Trimont Plaza
Pittsburgh, PA l52l1
(4l2) 38l-7000
THIS IS AN ATTEMPT TO COllECT
A DEBT AND ANY INFORMATION
OBTAINED W1LlIiIE USED FOR
THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
No. 01-6622
Plaintiff,
vs.
RICHARD B. BUCHER,
Defendant,
and
COMMERCE BANK,
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 RICHARD B. BUCHER, defendant, and .
3. against COMMERCE BANK, garnishee, (",5 A"5"J~ k (!.w1.<-5ko
4. and index this writ
a. against RICHARD B. BUCHER, 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 defendants
in anv accounts. individual and ioint. personal and business.
5.
Amount of Judgement
Additional Interest to Date
(Costs to be added)
$ 14,606.82 .;
$ 97.20
$
Pursuant to Writ of Execution
and Service of Writ $ 14,704.02
/(!kfJI () JmvYL
MICHELLE D. SMITH, ESQ.
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 01-6622
plaintiff,
TYPE OF PLEADING:
vs.
RICHARD B. BUCHER,
praecipe to Settle and
Discontinue Against Garnishee
ONLY
Defendant,
TYPE OF CASE:
and
Civil Action
COMMERCE BANK,
FILED ON BEHALF OF:
Garnishee.
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
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.
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IN THE COURT OF COMMON PLEAS OF
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CUMBERLAND COUNTY,
CIVIL DIVISION
PENNSYLVANIA
No. 01-6622
Plaintiff,
vs.
RICHARD B. BUCHER,
Defendant,
and
COMMERCE BANK,
Garnishee,
PRAECIPE TO SETTLE AND DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
please settle and discontinue this action against the above
garnishee, COMMERCE BANK and mark the docket accordingly.
Respectfully submitted,
MOLLICA & MURRAY
By: /iJ'J,dJb II c/Yn /(
CATHY ANN CHROMULAK, ESQ.
MICHELLE D. SMITH, ESQ.
Attorneys for Plaintiff
1305 Trimont Plaza
Suite 4504
Pittsburgh, PA 15211-1205
Sworn to and sub~ribed
befoFi= me this_1.~.~.''7 day
~rrJ1 . ~. 2002. ,
if{{juwJ~NA .
otary Pub.. ic
'_~Pldc
".~Ap~
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THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
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CERTIFICATE OF SERVICE
I, Michelle D. Smith, Esquire, counsel for HOUSEHOLD FINANCE
CONSUMER DISCOUNT COMPANY hereby certify that a true and correct
copy of the foregoing Praecipe to Settle and Discontinue Against
Garnishee Only was served upon the following by First Class Mail,
postage prepaid on this 13th day of MARCH, 2002:
COMMERCE BANK
65 Ashland Avenue
Carlisle, PA 17013
RICHARD B. BUCHER
37 North Baltimore Avenue
Mt. Holly Springs, PA 17007
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Michelle D. Smit , Esq.
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
t>l,
No. 6622 Civil Term
Plaintiff,
TYPE OF PLEADING:
VS.
RICHARD B. BUCHER,
Praecipe to Satisfy
Judgment
Defendant.
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:
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.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DMSION
01...
No. 6622 Civil Term
Plaintiff,
vs.
RICHARD B. BUCHER,
Defendant.
PRAECIPE TO SATISFY JUDGMENT
TO: PROTHONOTARY
Please satisfy the judgment against RICHARD B. BUCHER, at No. 6622 Civil
Term, and mark the docket accordingly.
Respectfully submitted,
MOLLICA & MURRAY
By:
.;Jl/4dfO)m IL
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MICHELLE D. SMITH, ESQ.
PA ID NO. 74800
Sworn to and Subscribed to
before me this ..i.D.- day of
~ "r.:. W002.
,
ttOJ. O'/lC~A CbAr~
Nota Iilic
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.
Notarial Seal
Debra Lyn Chiavetta, NOIaly Publi
City of Pittsburgh, Allegheny Coun C
My Commission &pires Ian. 29. 20:5';;
Member, PennaylVanJaAssocl8l1onofNotarlSi
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CERTIFICATE OF SERVICE
I, Michelle D. Smith, Esquire, counsel for Plaintiff, HOUSEHOLD FINANCE
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 --.42-lLday of September, 2002:
RICHARD B. BUCHER
37 North Baltimore Avenue
Mt. Holly Springs, P A 17007
1/lJ~/}bl/C
Michelle D. Smith, Esq.
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-6622 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONS. DISC. CO
PLANTIFF(S)
From RICHARD B. BUCHER
(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 COMMERCE BANK, 65 ASHLAND AVE., CARLISLE PA 17013.
GARNISHEE(S) as follows:
ANY PROPERTY OF DEFENDANT IN THE NAME OF GARNISHEE AND KINDLY SERVE
INTERROGATORIES..
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is/are 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 att.achment 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.
AmountDue $14,606.82
Interest $97.20
Atty's Comm %
Atty Paid $103.90
Plaintiff Paid
L.L.
$.50
$1.00
$.50
Due Prothy
Other Costs
STATE TAX
Date: FEBRUARY 19, 2002
CURTIS R. LONG
Prothonotary, Civil Division
REQUESTING PARTY:
Name MICHELLE D. SMTITH, ESQ.
Address: 1305 GRAND VIEW A VB.
45- TRIMONT PLAZA
PITTSBURGH PA 15211
Attorney for: PLAINTIFF
Telephone: (412) 3817000
Supreme Court ID No. 74800/
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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
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Garnishee
Advance Costs:
Sheriff sCosts:
150.00
73.38
76.62
18.00
1.43
.50
1.00
3.45
Refunded to Atty on 10/11 /02
20.00
20.00
9.00
73.38
So Answers;
Sworn and Subscribed to before me
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R. Thomas Kline, Sheriff t
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this jS-IL- day of mefk ,
2002 A.D. Q'i"CI. "thiIL. ,,44 /
pro onotary
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