HomeMy WebLinkAbout07-2491IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff, CIVIL DIVISION
Vs. /
No. 0AJ - 02q9 f ?L u LL 6
DANIEL P. FORSLUND
A/K/A DANIEL FORSLUND
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 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
r
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 OR 800-990-9108
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
IN THE COUNT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
i
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 0:?- a 'V-91 C? l
Plaintiff,
vs
TYPE OF PLEADING:
DANIEL P. FORSLUND
A/K/A DANIEL FORSLUND,
Defendant.
a
Plaintiffs Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
5402 OXFORD DRIVE #C
MECHANICSBURG, PA 17055
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION BTAINED WILL
BE USED FOR T AT PURPOSE.
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
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, LLC
375 Southpointe Boulevard
4`h Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
t
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 01- 2 Vg/ (4;Lf 7Zw..,_
Plaintiff,
vs.
DANIEL P. FORSLUND
A/K/A DANIEL FORSLUND,
Defendant.
COMPLAINT
6
AND NOW COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY, by its Attorneys, Chromulak & Associates, LLC, 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 situated at 2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred
to as "Plaintiff'.
2. DANIEL P. FORSLUND A/K/A DANIEL FORSLUND is an adult individual
residing at 5402 OXFORD DRIVE #C, MECHANICSBURG, PA 17055.
3. On' or about JANUARY 31, 2003, Defendant entered into a written Loan
Agreement with the Plaintiff, 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.
i
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 NOVEMBER 16, 2006.
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 FOUR HUNDRED
NINETEEN AND 26/100 ($4,419.26) DOLLARS as of MARCH 20, 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
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 FOUR
HUNDRED NINETEEN AND 26/100 ($4,419.26) DOLLARS, with interest thereon at the rate
of 25.698% from MARCH 20, 2007, plus court costs and attorney's fees.
Respectfully submitted,
Chromulak & Associates, LLC '6? By: 4'-'et
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
Attorneys for Plaintiff
THIS IS AN ATTEMPT TO 375 Southpointe Boulevard
COLLECT A DEBT AND ANY 4 Floor
INFORMATION OBTAINED WILL Canonsburg, PA 15317
BE USED FOR THAT PURPOSE.
LOAN REPAYMENT AND SECURITY AGREEMENT (Page 1 of 3)
LENDER (called "We", "Us", "Our")
HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY
25 GATEWAY DRIVE
GATEWAY SQUARE/SUITE 107
MECHANICSBURG PA 17055
BORROWERS (called "You", "Your") LOAN NO: 3440
FORSLUND, DANIEL P
SS# 2327
5402C OXFORD COURT
MECHANICSBURG PA 17055
TOTAL
01/31/2003
PAYMENTS
5_ 4,235.09 is 4,235.
LIFE INS PREMIUM DISABILITY INS PREMIUM
..._ __ i
NOR FILING INSURANCE PREMIUM
I NONE
REQUIRED INSURANCE. You must obtain insurance for term of loan covering security for this loan as indicated below,
naming us as Loss Payee:
Title insurance on real estate security.
Fire and extended coverage ins
Physical damage insurance on FEEXHIBIT bove if "Y" appears under "Insured".
Physical damage insurance on a urity" above if "Y" appears under "Insured".
You may obtain any required i se
(See "Security" paragraph a' insured.)
03-01-00 NR'E 111111111111111111111IN 111111111111111 ill PAS75011
xF37427137R99CEA9000PA8750110xxFORSLUND x ORIGINAL
LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3)
PAYMENT. In return for this loan, you will pay us the Total of Payments (the sum of Finance Charges plus Amount
Financed), in monthly payments stated on page one. The Finance Charge is the total of Interest plus Service Charge. You
may pay more at any time. You will pay us at our business address as stated on page one or other address given you. If
more than one Borrower is named on page one, we may enforce this Agreement against all, or any, Borrowers, but not in a
combined amount greater than the amount owed. I
DATE ON WHICH FINANCE CHARGE BEGINS. Finance Charges begin on theIdate of disbursement. If this loan is
made by mail, the date on which the Finance Charge begins is postponed by the number of days from the date of this
Agreement to the date of disbursement. Payment due dates and effective date of any optional insurance purchased are also
postponed. 1
PAY-OUTS. You agree to payouts of Amount Financed as shown on Truth-ln-llending disclosure form. If pay-outs
change because loan closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check will
be reduced to cover additional pay-outs.
PREPAYMENT. If you fully pay before final payment due date, the amount you owd will be reduced by unearned Finance
Charge (but not Service Charge) determined by the "Rule of 78ths". I
MATURITY. After the final payment due date stated on page one you will pay interest at the rate of 18% per year.
SECURITY. You agree to give us a security interest in the property identified-on page one, which will secure all
indebtedness, including future advances under this Agreement.
LATE CHARGE. If you don't pay any payment in 10 days after it's due, you will also pay 1 112% per month on the
amount overdue (subject to a $1.00 minimum charge).
BAD CHECK CHARGE. We will charge you a fee of $20 if 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 or fail to keep any rewired insurance in force, (a) all your
payments may become due at once and without notifying you before bringing suit, we may sue for the total amount you
owe less any unearned Finance Charges you would receive if you fully prepaid, and (b) you will also pay our reasonable
attorney fees, if the attorney is not our salaried employee, for legal proceedings to collect this loan or realize on security.
EXCHANGE OF INFORMATION. You understand that from time to time we may receive credit information
concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize us to share any
information, on a regular basis, we obtain related 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 include an inquiry to determine if you qualify for additional offers of credit. You also authorize us to
share any information regarding your Account with any of our affiliated corporations, subsidiaries or other third parties.
You may prohibit the sharing of such information (except for the sharing of information about transactions or
experiences between us and you) by sending a written request which contains your full name, Social Security
Number and Address to us at P.O. Box 1547, Chesapeake, VA 23320.
If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be
submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent
of such department) may release your residence address to us, should it become necessary to locate you. You agree that
our supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the
quality of our service to you. '
INSURANCE. Optional credit insurance and any required insurance disclosures are attached to this Agreement and are
incorporated herein by reference.
ALTERNATIVE DISPUTE RESOLUI'ION AND OTHER RIDERS. The terms of the Arbitration Agreement and any
other Riders signed as part of this loan transaction are incorporated into this Agreement by reference.
APPLICABLE LAW. The Pennsylvania Consumer Discount Company Act (CDCA), Title 7, Purdon's Pennsylvania
Statutes, governs this loan.
NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONA I CONTRACT TERMS.
03-01-00 NRE
PAB75012
1011IIIM IIIII01111111M1IIII1I111RMIIIIIIIII11I1NIIIIMIN
xF37427137R99CEA9000PA6750120xxFORSLUND x I ORIGINAL
LOAN' REPAYMENT AND SECURITY AGREEMENT (Page 3 of 3)
YOU HAVE RECEIVED A COMPLETE
COPY OF THIS AGREEMENT AND THE
TRUTH-IN-LENDING DISCLOSURES.
BORR RS:
(SEAL)
(SEAL)
WITNESS: (SEAL)
LAI
03-01-00 NRE
PAS75013
KF37427137R99CEA9000PA8750130*NFORSLUND K ORIGINAL
TRUTH-IN-LENDING DISCLOSURES (Page 1 of 2)
LENDER (Called "We", "Our", "Us")
HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY
25 GATEWAY ORIVE
GATEWAY SQUARE/SUITE 107
MECHANICSBURG PA 17055
BORROWERS (Called "You", "Your") LOAN NO:
FORSLUND, DANIEL P
54020 OXFORD COURT
MECHANICSBURG PA 17055
• ANNUAL • FINANCE Amount Total of Payments Date
PERCENTAGE CHARGE Financed The amount you will of
RATE
The dollar amount The amount of credi have paid after you Loan
The cost of your credit
the credit will cost provided to you or o have made all pay-
you. your behalf. ments as scheduled.
as a yearly rate.
25.698% $ 4235 09
$ 5390.11 $ 9525.20 01/31/03
Your a went schedule will be:
AN4umber of Payments Amount of Payments When Payments Are Due
8440
$ 150.42 03/01/03
059 $ 160.42 Day 01 of each month thereafter.
Late Charge: If you don't pay any payment in 10 days after it's due, you will also pay 1 112% per month on the
amount overdue (subject to a $1.00 minimum charge).
Prepayment: If you pay off early, you may be entitled to a refund of part of the Finance Charge.
See the contract documents for any additional information about nonpayment, default, any required repayment
in full before the scheduled date, and prepayment refunds.
NOTICE: The following page contains additional information.
11-26-02 NRE TIL
P0.818t11
?II?I Iq ? III IAA ? ? ? ? ? II I? {N{II INI ?I ID ? ? N? ICI ?I ? ? i? ? ID ? I Iii
KF37427137R99FED9000PA81811109sFORSLUND * ORIGINAL
i
TRUTH-IN-LENDING DISCLOSURES (Page 2 bf 2)
ITEMIZATION OF THE AMOUNT FINANCED I
CREDIT LIFE INSURANCE (PAID TO INSURANCE COMPANY).........,
CASH OR CHECK TO BORROWER,,,,,,,,,,,,,
AMOUNT FINANCED...........,
I
190.29
5199.82
5390.11
I
11-26-01 NRE TIL I
PASIS112
ling 1111111
OPA9181120 FORSLUND
Ii ORIGINAL
f
VERIFICATION
D IANNA WIGGINS , Recover Specialist for
HOUSEHOLD FMANC E CONSUL' M DISCOU, CWMDJV
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.
DIANNA WIGGINS
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
DANIEL P. FORSLUND A/K/A
DANIEL FORSLUND,
Defendant.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
5402 OXFORD DRIVE, #C
MECHANICSBURG, PA 17055
Dated: JUNE 12, 2007
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND
ANY INFORMATION
OBTAINED WILL BE USED
CIVIL DIVISION
No. 07-2491 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, ESQUIRE
PA ID NO. 42067
MAUREEN A. DOWD, ESQUIRE
PA ID NO. 90549
BETH ARNOLD HOWELL, ESQUIRE
PA ID NO. 203606
CHRISTINE A. SAUNDERS, ESQUIRE
PA ID NO. 203373
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
FOR THAT PURPOSE.
TO:PROTHONOTARY
Please enter judgment by default against the within-named defendant, DANIEL P.
FORSLUND A/K/A DANIEL FORSLUND, for failure to file an Answer as follows:
Amount Claimed in Complaint: $4,419.26
Interest from 3/21/07 through 6/12/07: 183.07
Costs of Collection through 6/12/07: 531.06
TOTAL $5,133.39
With interest accruing on the total balance of $5,133.39 at the rate of 6% per annum, together
with additional costs of suit.
CATHY ANN CHROMUL`AK, 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:
Public in and for said County and State,
Before me, the undersigned au o 6y, -a Notary
personally appeared, t ?L t l.?U , 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 MAY 30, 2007 by certificate of mailing in accordance
with Pa.R.C.P. 237.1, as evidenced by the attached copy..
CATHY ANN C OMI LAK, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
BETH ARNOLD HOWELL, ESQUIRE
CHRISTINE A. SAUNDERS, ESQUIRE
Sworn to and subscribed before me
This day of , 2007.
"14V C464_4a
Notary Publi
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08d Twp., Waaht om OMX*
My ComrtMesion E fires AM 29, 2010
Member, PennevvW18 Areodedw of Notmtet
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND
ANY INFORMATION
OBTAINED WILL BE USED
FOR THAT PURPOSE.
... Y.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION
DISCOUNT COMPANY, No. 07-2491 CIVIL TERM
Plaintiff,
Vs.
DANIEL P. FORSLUND A/K/A
DANIEL FORSLUND,
Defendant(s).
TO: DANIEL P. FORSLUND A/K/A
DANIEL FORSLUND
5402 OXFORD DRIVE #C
MECHANICSBURG, PA 17055
DATE OF NOTICE: MAY 30, 2007
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 WITHIN TEN 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 AVENUE
CARLISLE, PA 17013
717-249-3166 OR 800-990-9108
By:
CATHY ANN CHROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, ESQ.
THIS IS AN ATTEMPT TO CHRISTINE A. SAUNDERS, ESQ.
COLLECT A DEBT AND ANY Attorneys for Plaintiff
INFORMATION OBTAINED WILL 375 Southpointe Boulevard
BE USED FOR THAT PURPOSE. 4t' Floor
Canonsburg, PA 15317
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
No. 07-2491 Civil Term
Plaintiff,
VS.
DANIEL P. FORSLUND A/K/A
DANIEL FORSLUND,
Defendant.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: DANIEL P. FORSLUND A/K/A DANIEL FORSLUND
5402 OXFORD DRIVE, #C
MECHANICSBURG, PA 17055
(X) Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above
captioned proceeding on >p aCep
T
() A copy of the Order or Decree is enclosed, or
(X) The judgment is as follows: $5,133.39 plus interest at the rate of 6% per
annum and additional costs of suit.
(57- t:T41
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND
ANY INFORMATION
OBTAINED WILL BE USED
FOR THAT PURPOSE.
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-02491 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS
FORSLUND DANIEL P ET AL
SHARON LANTZ , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
FORSLUND DANIEL P A/K/A DANIEL FORSLUND the
DEFENDANT , at 1055:00 HOURS, on the 9th day of May 2007
at 5402 OXFORD DRIVE #C
MECHANICSBURG, PA 17055 by handing to
DANIEL P FORSLUND
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 10.56
Affidavit .00
Surcharge 10.00
.00
5/?afp? 38.56
Sworn and Subscibed to
before me this day
of ,
So Answers: R. Thomas Kline
05/10/2007
CHROMULAK & ASSOCIATES
By.
A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 07-2491 CIVIL TERM
Plaintiff,
VS.
DANIEL P. FORSLUND a/k/a
DANIEL FORSLUND,
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
Defendant,
and
M&T BANK,
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
5402 OXFORD DRIVE, #C
MECHANICSBURG, PA 17055
Garnishee's Address:
1 WEST HIGHT STREET
CARLISLE, PA 17013
Date: August 17, 2007
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
Plaintiff,
vs.
No. 07-2491 CIVIL TERM
DANIEL P. FORSLUND a/k/a DANIEL FORSLUND,
Defendant,
and
M&T 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 DANIEL P. FORSLUND a/k/a DANIEL FORSLUND, defendant, and
3. against M&T BANK, garnishee,
4. and index this writ
a. against DANIEL P. FORSLUND a/k/a DANIEL FORSLUND, defendant, and
b. against M&T 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)
$5,133.39
$ 55.04
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.
$5,188.43
CGS ?iGu,??
CATHY ANN CHROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
BETH ARNOLD HOWELL, ESQ.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-2491 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY Plaintiff (s)
From DANIEL P FORSLUND a/k/a DANIEL FORSLUND, 5402 OXFORD DRIVE, #C,
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:
M&T BANK, 1 WEST HIGH STREET, 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 $5,133.39
Interest to Date - $55.04
Atty's Comm %
Atty Paid $158.06
Plaintiff Paid
Date: 8/20/07
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
Curti A. Long, Protho
By:
Deputy
REQUESTING PARTY:
Name CHRISTINE A. SAUNDERS, ESQUIRE
Address: CHROMULAK & ASSOCIATES, LLC
375 SOUTHPOINTE BLVD., 4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203373
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
DANIEL P. FORSLUND a/k/a
DANIEL FORSLUND,
5402 OXFORD DRIVE, #C
MECHANICSBURG, PA 17055
Defendant,
and
M&T BANK
Garnishee.
TO: M&T BANK
1 WEST HIGH STREET
CARLISLE, PA 17013
CIVIL DIVISION
No. 07-2491 CIVIL TERM
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.
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:
Sul & T BANK
NAS NO OPEN ACCOUNT &
FOR AROVF NAMEf
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:
THIS IS AN ATTEMPT To
COLLECT A DEBT AND ANY
INFORMATION OBTAINED MALL
BE USED FOR THAT PURPOSE.
0
T D: 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:
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:
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:
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:
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:
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
L
Ar
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:
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:
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:
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:
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:
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
01,
,s
i? 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:
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 fluids 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:
DATE: 4-0 -
CATHY S. FISHER
MU BANK
AUG 2 4 W
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. 6&.- ? y
Cathy Ann Chromul sq.
Maureen A. Dowd, Esq.
Christine A. Saunders, Esq.
Beth Arnold Howell, Esq.
375 Southpointe Boulevard
4'' Floor
Canonsburg, PA 15317
(724) 916-2400
01
a
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-02491 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS
FORSLUND DANIEL P ET AL
And now RONALD HOOVER Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:46 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
FORSLUND DANIEL P A/K/A DANIEL FORSLUND
hands, possession, or control of the within named Garnishee
M & T BANK 1 WEST HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
in the
COURTNEY CROWL (TELLER) ,
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 r
Docketing .00 Service .00 Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
.00,/ 31af/b7
08/24/2007
Sworn and Subscribed to
before me this day of By
Deputy She iff
A.D
A . F.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
DANIEL P. FORSLUND a/k/a
DANIEL FORSLUND,
5402 OXFORD DRIVE, #C
MECHANICSBURG, PA 17055
Defendant,
and
M&T BANK
Garnishee.
TO: M&T BANK
1 WEST HIGH STREET
CARLISLE, PA 17013
CIVIL DIVISION
No. 07-2491 CIVIL TERM
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.
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:
M & T BANK
HAS NO OPEN ACCOUNT,
FOR ABOVE NAME['
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:
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
ow
THIRD: 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:
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:
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:
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:
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:
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:
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:
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:
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:
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:
THIS Is AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
?w
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:
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:
DATE: LT- 4-0 -7
CATHY S. FISHER
M&T BANK
per, 2 3 W
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:
Cathy Ann Chromul , sq.
Maureen A. Dowd, Esq.
Christine A. Saunders, Esq.
Beth Arnold Howell, Esq.
375 Southpointe Boulevard
4t' Floor
Canonsburg, PA 15317
(724) 916-2400
n's?r tTt-
J''" i
?
G
lt
C..3
Ir4'THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
V
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
DANIEL P. FORSLUND a/k/a
DANIEL FORSLUND,
Defendant,
and
M&T BANK,
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Garnishee.
Defendant's Address:
5402 OXFORD DRIVE #C
MECHANICSBURG, PA 17055
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CIVIL DIVISION:
No. 07-2491 CIVIL TERM
TYPE OF PLEADING:
Praecipe to Discontinue
Against Garnishee ONLY
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
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
4th Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
CIVIL DIVISION:
No. 07-2491 CIVIL TERM
DANIEL P. FORSLUND a/k/a
DANIEL FORSLUND,
Defendant,
and
M&T BANK,
Garnishee.
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO THE PROTHONOTARY:
Please discontinue this action against the above garnishee, M&T BANK, and mark the
docket accordingly.
Sworn to and subscribed
Before me this 3 day
of , 2007.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By:
CATHY ANN CHR MULAK, ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
{?.
Notary Pill "icc
COMMONWEALTH OF PENNSYLVANIA
Notarial Seel
Heather L. Hatfield, Notary Public
Cecil Twp., Washington County
My Commission Expires June 29, 2010
!Member. Pennsvlvania Association of Notariee
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
,•
CERTIFICATE OF SERVICE
I, counsel for HOUSEHOLD FINANCE 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 31st day of
August, 2007.
M&T BANK
CATHY FISHER
P.O. BOX #844
BUFFALO, NY 14240
DANIEL P. FORSLUND a/k/a
DANIEL FORSLUND
5402 OXFORD DRIVE #C
MECHANICSBURG, PA 17055
l
Cathy Ann Chromula sq.
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.
04 }
f
7-1
{7
cp
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
CIVIL DIVISION
vs.
DANIEL P. FORSLUND
a/k/a DANIEL FORSLUND,
Defendant,
and
PNC BANK,
No. 07-2491 Civil Term
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
Garnishee.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
5402 OXFORD DRIVE #C
MECHANICSBURG, PA 17055
Garnishee's Address:
105 NOBLE BLVD
CARLISLE, PA 17013
Date: November 29, 2007
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
{ . ".%
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
vs.
DANIEL P. FORSLUND
a/k/a DANIEL FORSLUND,
and
PNC BANK,
SOS NoWe 6W
Plaintiff,
CIVIL DIVISION
No. 07-2491 Civil Term
5y0a OXFORD oe,1V E kC
HECK. PA 17055
Defendant,
&d(sle, PA 17011 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 DANIEL P. FORSLUND a/k/a DANIEL FORSLUND, defendant, and
3. against PNC BANK, garnishee,
4. and index this writ
a. against DANIEL P. FORSLUND a/k/a DANIEL FORSLUND, defendant, and
b. against PNC 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)
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.
$5,133.39
$ 143.62
$5,277.01
(1444, CATHY ANN C MULAK, ESQ.
MAUREEN A. DOWD, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
BETH ARNOLD HOWELL, ESQ.
P ?
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_
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-2491 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY, Plaintiff (s)
From DANIEL P. FORSLUND a/k/a DANIEL FORSLUND, 5402 Oxford Drive #C, Mech., 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:
PNC BANK, 105 Noble Blvd., Carlisle, PA 17013
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 $5,133.39
Interest to Date -- $143.62
Atty's Comm %
Atty Paid $188.06
Plaintiff Paid
Date: 12/07/07
(Seal)
L.L.
Due Prothy $2.00
Other Costs
s R. Long, Prothonotart
By:
At R
t
Deputy
REQUESTING PARTY:
Name CHRISTINE A. SAUNDERS, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD, 4TH FLR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203373
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff's Costs: Advance Costs: 150.00
Sheriff's Costs: 87.61
Docketing 18.00 $ 62.39
Poundage 1.72
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 12/27/07
Mileage 4.80
Surcharge 30.00
Levy 20.00
Certified Mail
Post Pone Sale
Garnishee 9.00
Postage
TOTAL $
87.61 ?n
j4" So Answers;
R. Thomas Kline, Sheriff
,a 7
By Claudia A. Brewba
?J
;U
I'**
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-2491 Civil
CIVIL ACTION - LAW
11
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY, Plaintiff (s)
From DANIEL P. FORSLUND a/k/a DANIEL FORSLUND, 5402 Oxford Drive #C, Mech., 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:
PNC BANK, 105 Noble Blvd., Carlisle, PA 17013
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 $5,133.39
Interest to Date -- $143.62
Atty's Comm %
Atty Paid $188.06
Plaintiff Paid
Date: 1/09/08
(Seal)
REQUESTING PARTY:
L.L.
Due Prothy $2.00
Other Costs
s R. Long, Prothonota
By:
i
Deputyl?-
Name CHRISTINE A. SAUNDERS, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD, 4TH FLR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203373
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-02491 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS
FORSLUND DANIEL P ET AL
And now NOAH CLINE Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:00 Hours, on the 10th day of January , 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
FORSLUND DANIEL P A/K/A DANIEL FORSLUND , in the
hands, possession, or control of the within named Garnishee
PNC BANK 105 NOBLE BLVD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
D. KATIE STOUFFER (FIN. SALES CONS) ,
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
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00 00
01/10/2008
Sworn and Subscribed to
before me this day of By
eputy Sheriff
A.D
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
6
CIVIL' DIVISION:
No. 07-2491 CIVIL TERM
vs.
DANIEL P. FORSLUND
A/K/A DANIEL FORSLUND,
Defendant,
and
TYPE OF PLEADING:
Praecipe to Discontinue
Against Garnishee ONLY
PNC BANK,
TYPE OF CASE:
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Civil Action
FILED ON BEHALF OF:
HOUSEHOLD FINANCE 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
TERESA K. GABRIEL, ESQ.
PA ID NO. 205696
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
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
DANIEL P. FORSLUND
A/K/A DANIEL FORSLUND
and
Defendant,
CIVIL DIVISION:
No. 07-2491 CIVIL TERM
PNC BANK,
Garnishee.
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO THE PROTHONOTARY:
Please discontinue this action against the above garnishee, PNC BANK, and mark the
docket accordingly.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seel
Heather L Hatfield, Notary Public
Cecil Tv6p., Washington County
My Commission Epires June 29, 2010
Member, Pennsylvania Association of Notaries
Sworn to and subscribed
Before me this 24t" day
of - , 2008.
Notary Public
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By:
CATHY ANN CHROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
TERESA K. GABRIEL, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CERTIFICATE OF SERVICE
I, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, herdby
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 21ST day of
JANUARY, 2008.
PNC BANK
FIRSTSIDE CENTER
500 FIRST AVENUE
PITTSBURGH, PA 15219
DANIEL P. FORSLUND
A/K/A DANIEL FORSLUND
5402 OXFORD DRIVE #C
MECHANICSBURG, PA 17055
Cathy Ann Chr ulak, Esq.
Maureen A. Dowd, 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`
7, l'o
r
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:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Milage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
Advance Costs: 150.00
85.48
18.00 64.52
1.68
Refunded on 10/30/08
2.00
4.80
30.00
20.00
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9.00 So Answers,
85.48 ? Je f o 4 ?D '`?
R. T mas Kline, Sheri
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?i?Pa(
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-2491 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY, Plaintiff (s)
From DANIEL P. FORSLUND a/Wa DANIEL FORSLUND, 5402 Oxford Drive #C, Mech., 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:
PNC BANK, 105 Noble Blvd., Carlisle, PA 17013
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 $5,133.39
Interest to Date -- $143.62
Atty's Comm %
Atty Paid $188.06
Plaintiff Paid
Date: I /0910$
(Seal)
REQUESTING PARTY:
L.L.
Due Prothy $2.00
Other Costs
rtis R. Long, Prothonotal
By:
Deputy
Name CHRISTINE A. SAUNDERS, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD, 4"H FLR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203373