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ORIGINAL
HAYT, HAYT & LANDAU
BY: ARTHUR LASHIN, ESQUIRE
IDENTIFICATION NO 23425
SIXTH FLOOR
400 MARKET STREET
PHILADELPHIA, PA 19106-2509
(215) 928.1400
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
HOUSEHOLD BANK (SB), N.A. COURT OF COMMON PLEAS
1111 Town Center Drive CIVIL DIVISION
Las Vegas, Nevada 89128
VS. , TERM,
GILANNE WOHLFARTH
1501-7 William Grove Road
Mechanicsburg, Pennsylvania 17055 No. ?? S93a
CIVIL ACTION
"NOTICE
"You nave often sued in court. If YOU Hnn to defend against
the claims set forth m tn0 following Pages, You must take action
Wrtmn twenty 1201 da vs after inn c-molmnt and ndtC, are served,
by entering a Written 100WranCif Personally or by attorney and
I-IIPg in wl,tmg with tn. Courl your oerenses or doleCtions to the
Ciii set forth against you. You are warned that if you fan to do
so ins Casa may Ordeeed vwdnout You and a ludgmiint may be on.
,fired against you by fine court w, t nout further notice for any mom
W claimed in trio Complaint or for any other Claim or relief request.
ea Py the Olam!ilf. You may lose money or prooerty or other rights
,mdortant to you.
"YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AF-
FORD 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, Pennsylvania 17013
(717) 249-3166
"AV ISO
`Le man atmandao0 a "led on la Curie. Si .%teo Quiet.
delenderse de offal aem ods ea QUeStJS en 'as daginas sigwentas.
I tiene veinte (201 danl, de Ola[o al Oartu de It OCha de to
deni y to no ti bCa UOn, HaCe falls afenlar una ComdaranCla
elcnN o an persona a Con un apogaaa IF entregar a to Corte on
Form' escnta Sus defenses o Sus oplaciOnes a 41 demandas on
Contra de su Colons. Sea av,Sado QUO Si uSled no se dallenda, o
Corte lomar$ m.oloas y FUSCO Continuer la demand, on Contra
Suva Sin orevit, avlsa o notmuCIS.. Adel-4f, la Carle outdo
aeciaU a favor dal demandante y reouien Qua Ulod Carroll Con
Coal 14S drOvSIOnet ae alts demanda. Ustea puaoe Potosi dlnero
O Sus otoo,eaades u -trot darachal Imporbntas Cara usteo.
"LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE. SI NO TIENE A130GADO0 Si NO
TIENE EL OINEPO SUFICIENTE OE PAGyR TAIL SERVICIO,
VAYA EN PERSONA O LLAME POR TELFONO A LA
OFICINA CUYA DI RECCICEN SE ENCUENTRA ESCRITA
ASAJO PARA AVERIGUAR OONOE SE PUEDE CONSF-GUTA
ASISTENCIA LEGAL.
^Y
CIVIL ACTION
1. Plaintiff, Household Bank (SB), N.A., is a corporation
organized and existing under the laws of the State of Nevada,
authorized to do business in the Commonwealth of Pennsylvania with
offices located at 1111 Town Center Drive, Las Vegas, Nevada 89128.
2. The Defendant(s) Gilanne Wohlfarth is/are individual(s)
residing at the address(es) contained in the caption of this case.
3. Through accident and without any fault or negligence on the
part of Plaintiff, the original contract in this matter was
inadvertently lost or destroyed, a true and correct copy of the
Affidavit of Lost Note being attached hereto, made a part hereof,
and marked Plaintiff's Exhibit "A".
4. Though diligent search and inquiry have been made, Plaintiff
cannot ascertain the current whereabouts of the original contract.
5. General Motors Credit Card Services set over unto Plaintiff
all of its right, title and interest in and to its account with
Defendant(s) so that Plaintiff is now owner of said account.
6. Pursuant to the Affidavit of Lost Note there is presently an
outstanding balance as outlined below:
Unpaid balance: $954.09
Interest due: 83.20
Attorney's fees at 10%: 103.72
Total due: $1,141.01
7. Despite repeated demand by Plaintiff, Defendant(s) has/have
failed and refused to pay the aforesaid sum.
WHEREFORE, Plaintiff demands that judgment be entered against
Defendant(s) in favor of Plaintiff in the amount of $1,141.01
together with interest and costs.
HAY
By:
Attorney for Plaintiff
State of Nevada)
County of Clark)ss
AFFIDAVIT OF DESTROYED INSTRUMENT
HOUSEHOLD BANK (SB), N.A.
Deponent
Defendant(s): Wohlfarth. Gilanne Account No.: 5437000213360128
The undersigned being duly sworn, states and deposes as follows:
1. That he is employed by Household Bank (0), N.A. in the position
of Department Manager.
2. That he is duly authorized to make this affidavit and is
familiar with the subject account.
3. That he is the keeper of the books and records.
4. That the original contract in this matter has been destroyed,
or is no longer accessible to the deponent.
5. This affidavit is to be treated as the original document for
all purposes and if any originals are discovered, they will be
submitted to the court for cancellation.
6. There is presently an outstanding balance of $ /S-v 4)4? plus
interest at the contract rate ofp?6F, 9o percent frr ILh? and
reasonable attorney fees if applicable, due upon defai, i 7
HOUSEHOLD BANK (SB), N.A.
By: b<--
Pat k Graham, Department Manager
Subscri and .awgrni.? ,tto before me in the state of Nevada this day of y1998. --
?? (Seal)
Notary Public
?rs
4.
My Commission expires: ---
cXl•IRIT ,.p„
STATE OF NEVADA
SS
COUNTY OF CLARK
AFFIDAVIT
David Robinson, being duly sworn according to law, deposes and says
that he is Department Manager for Household Bank (SB), N.A., and
that he is duly authorized to take this Affidavit on behalf of
Household Bank (SB), N.A., and that the facts contained in the
attached pleading are true and correct to the best of his
information, knowledge and belief.
David Robinson
Department Manager
Sworn to and subscribed
before me this day
of a 1?1?1
L
Notary Public
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-05932 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD BANK (SB) N A
VS.
WOHLFARTH GILANNE
SHAWN HARRISON , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within CIVIL ACTION was served
upon WOHLFARTH GILANNE the
defendant, at 9:00 HOURS, on the 4th day of October
1999 at 1501-7 WILLIAMS GROVE ROAD
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to GILIANNE WOHLFARTH
a true and attested copy of the CIVIL ACTION
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Affidavit 5.00ck 2
Surcharge 8.00 comas ine, eri
0%06/1999 & DAU y
by
e u y i
Sworn and subscribed to before me
this ,2 «.( day of
19 (q/q A.D.
rotonoE r
041(2144`
HAYT, HAYT & LANDAU
BY: ARTHUR LASHIN, ESQUIRE
IDENTIFICATION NO. 23425
SIXTH FLOOR
400 MARKET STREET
PHILADELPHIA, PA 19106-2509
(215) 928.1400
ATTORNEY FOR PLAINTIFF
HOUSEHOLD BANK (SB), N.A.
VS.
GILANNE WOHLFARTH
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM.
No. 99-5932 CIVIL
ORDER TO DISCONTINUE, SETTLE AND END
TO THE PROTHONOTARY:
Kindly mark the above captioned matter discontinued, settled and ended upon
payment of your costs only.
HAYT, HAYT & LANDAC?
By:
Attorney for Plaintiff
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