HomeMy WebLinkAbout07-4176~~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY CIVIL DIVISION
Plaintiff, No. 07 - ~ ~ 7!• 1..~ V' l l errr-
Vs.
ILONKA C. WEAVER
and
HELGA T. WALKER
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
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 HAKE 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 O$TAINED WILL
BE USED FOR THAT PURPOSE
~,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
Plaintiff,
vs.
ILONKA C. WEAVER
and
HELGA T. WALKER
Defendants.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendants' Address:
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
TYPE OF PLEADING:
Complaint
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID N0.42067
MAUREEN A. DOWD, ESQ.
PA ID N0.90549
BETH ARNOLD HOWELL, ESQ.
PA ID NO.203606
CHRISTINE A. SAUNDERS, ESQ.
PA ID N0.203373
CHROMULAK & ASSOCIATES, LLC
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY, CIVIL DIVISION
Plaintiff, No. d 7 - Sf I~4 (~tuLl ~c~-+
vs.
ILONKA C. WEAVER
and
HELGA T. WALKER,
Defendants.
COMPLAINT
AND NOW COMES, the Plaintiff, BENEFICIAL CONSUMER DISCOUNT
COMPANY, by its Attorneys, Chromulak & Associates, LLC, with its Civil Action
Complaint, the following of which is a statement thereof:
1. BENEFICIAL CONSUMER DISCOUNT COMPANY is a Corporation, duly
authorized to conduct business in the Commonwealth of Pennsylvania, with its principal office
situated at 2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred to as "Plaintiff'.
2. ILONKA C. WEAVER and HELGA T. WALKER are adult individuals residing
at 17 PINE HILL AVENUE, MECHANICSBURG, PA 17050.
3. On or about AUGUST 19, 2004, Defendants 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 the Defendants, Plaintiff advanced funds to
the Defendants.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
5. Defendants are 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 OCTOBER 31, 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 Defendants is in the sum ofTWENTY-THOUSAND THREE-
HUNDRED EIGHTY-SEVEN and 83/100 ($20,387.83) DOLLARS as of MAY 30, 2007.
7. Numerous demands have been made upon the Defendants by Plaintiff, but the
Defendants have flailed 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.
WHERE>~~ORE, Plaintiff claims damages in the sum ofTWENTY-THOUSAND
THREE-HUNDRPD EIGHTY-SEVEN and 83/100 ($20,387.83) DOLLARS, with interest
thereon at the rate'of 22.98% from MAY 31, 2007, plus court costs and attorney's fees.
Respectfully submitted,
Chromulak & Associates, LLC
By: l 'v~"LK~
CATHY ANN CHROMULAK, ESQ.
PA ID N0.42067
MAUREEN A. DOWD, ESQ.
PA ID N0.90549
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.
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 1 of 4)
LENDER (called "We", "Us", "Our")
BENEFICIAL CONSUMER DISCOUNT COMPANY
4910 CARLISLE PIKE
SUITE 104-HAMPDEN CENTER
MECHANICSBURG PA 17050
BORROWERS (called "You", "Your") LOAN NO:
WEAVER, ILONKA C
SS#
WALKER, HELGA T
SS#
17 PINE H1LL AVE
MECHANICSBURG PA 17050
ON
01 AND OVER 1.915 X ~ 22.980 X
a
In this Agreement, "you", "your" and "Borrower" mean the customer{s) who signs this Agreement. "We", "us", snd
"our" refer to Lender. This Agreement covers the terms and conditions of your Personal Credit Line Account. We want
you to understand how your Personal Credit Line Account works. Read this carefully, ask us any questions, and if you
agree to be bound by this Agreement, sign below. If more than one person signs, each will be responsible for repaying all
sums advanced under this Agreement.
Your Credit Line Account is a revolving line of credit extended to you and secured as described below. You can obtain
funds from your Personal Credit Line Account (up to your credit limit} directly from us or by using the special checks we
supply to you. You may pay your total unpaid balance at any time or in installments.
REQUIRED INSURANCE. You muse obtain insurance for farm of loan covering security for this loan ngreement es indicated by
the word "YES" below, naming ua as Lola Pnyoe:
Physical dmm~ga inauraaee on vehicle listed under "Security" above, if "Y" appears wader 'Iasured."
You may obtsia aay requiredsasursace from sayoae you choose.
NOTICE: SEE THE FOLLOWING PAGES FOR ADDrrI ANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE
BIwNG ERRORS. {~~~i~11~~® EXHIBIT ~~~~~~I~ryM~ pA066361
F3NRE_~ ` ORIGINAL
"Yf1518252AB85RLA8000PA056 l~ ~II
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 2 of 4}
Available Credit: You may obtain funds directly from us or through your special checks up to your available credit. Each
c oc c must a wntten for at least $100.00. Your available credit is your credit limit (shown on page one} less the total
unpaid balance, including Finance Charges, of your Account. If you make loan payments by check, we will adjust your
available credit seven days after we receive your check to allow for check clearing. If you request funds in an amount that
would cause you to exceed your available credit, we are not obligated to honor your request. If we do lend you an amount
over your available credit, you agree to pay uB that excess amount, plus Finance Charges, immediately.
Promise to Pay: You promise to pay Lender: (a) amounts borrowed under this Agreement; (b) Finance Charges,
minlstratlve ''?•iarges {the late charge and bad check charge) and other charges provided in this Agrcement; (c) credit
insurance charges, if any; (d} collection costs permitted by applicable law, including reasonable attorneys' fees; and (e)
amounts in excess of your credit limit that we may lend you, plus Finance Charges.
Payments: You may repay your entire outstanding balance at any time without penalty. You may not use your special
c ec to pay any amounts due under this Agreement. Because the Finance Charge is computed each day, you will contact
us regarding the exact payoff amount for the day you intend to make full payment. If you do not pay the entire unpaid
balance on your Account at once, you agree to pay at least the minimum payment shown on your monthly statement.
Payments will be applied as follows: First, to any accrued but unpaid Finance Charges; Second, to any unpaid
Administrative Charges {the late charge and bad check charge); Third, to any unpaid credit insurance charges; and Fourth,
to the outstanding balance of your Account. Any part of your monthly payment to be applied to amounts borrowed on
your Account will be applied to the amounts borrowed under your Personal Credit Line Account in the order in which the
amounts were borrowed. Any part of your monthly payment to be applied to Finance Charges will be applied in the same
manner.
Minimum Monthly Payment: The Minimum Monthly Payment for any billing cycle will be the greater of (1) the
greater o or t e ayment mount (as described below) plus any Administrative Charges and credit insurance charges,
rounded to the nearest $1; or {2) the Finance Charges due for the billing cycle plus any Administrative Charges and credit
insurance charges; or {3) the amount of the Annual Fee assessed to your Account. In each instance the Minimum Monthly
Payment will be adjusted to include any unpaid amounts due from previous billing cycles.
The Payment Amount depends on the monthly periodic rate applicable to your Account, and is calculated as follows:
Monthly Periodic Rate
t roug
over 1.33% through 1.45°!
over 1.45% through 1.57%
over 1.57°b through 1.70%
over 1.70% through 1.83%
over 1.83°,b through 1.95%
over 1.95%
Payment Amount
. ~ o ccount Balance
1.55% of Account Balance
1.67% of Account Balance
1.80°b of Account Balance
1.93% of Account Balance
2.00% of Account Balance
2.15°b of Account Balance
Finance Charges: This is the interest charged on the balance of your Account during each billing cycle. The Finance
arge ~s ca cu aced from the date that each advance, check or charge is posted to your Account. The Finance Charge is
computed by multiplying the average daily balance in your Account in each billing cycle times the monthly periodic rate
stated on page one. The average daily balance is determined by totaling all daily unpaid balances in each billing cycle and
dividing the total by the number of days in that cycle (but not less than thirty). A daily unpaid balance is.the amount owed
each day, excluding any unpaid Finance Charge, Administrative Charges, and credit insurance charges for prior billing
cycles.
Annual Fee: You agree to pay an Annual Fee as stated on page one far participation in this revolving credit plan. The
nltla nnua Fee is stated on page one and is due and payable on the date that your Account is established, and the
subsequent Annual Fee stated on page one is due and payable on the same day of each subsequent year. You agree that this
fee may be charged to your Account balance.
Bad Check Charge: If you pay by a check which is returned for any reason, you agree to pay a bad check charge of $20.
Late Charge: If you do not pay any required Minimum Monthly Payment within 15 days after it is due, you agree to pay
a ate c arge of 10% of the Minimum Monthly Payment due or $20, whichever is greater (excluding any unpaid late
charges and amounts due from prior billing cycles).
NOTICE SEE THE FOLLOWING PAGES FOR ADDfTIONAt PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING
ERRORS.
F3~OE1-00
I~III~~~II~I~~III~~II~~~~~~~~II~I~~WWI~~IIIBI~I~~~~~ PA056362
~Yl15iB252AB85RLAe000PA0563620KMWEAVER
ORIGINAL
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 3 of 4)
Other Charges: You agree to pay any amounts actually incurred by Lender for services rendered in connection with the
ersona 1t Line Account for fees paid to public officials in connection with perfecting, recording, releasing or
satisfying a security interest in the security. You agree that these fees may be charged to your Account balance.
Exchange of Information: You understand that from time to time we may receive credit information concerning you
rom of ers, sue 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 betweea
us and you) by seeding s 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 sgrce 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.
Termination and Changes in the Agreement: We: can terminate your right to obtain additional advances or
c ange t e terms o t 1s greement, ><nc u >Ing increasing the rate of Finance Charge at aay time. Prior written
notice will be given to you when required by applicable law unless you consent to the change before chat time.
Changes may apply to both new and outstanding balances unless prohibited by applicable law.
Default and Cancellation of Agreement: We have the right to require you to pay your entire balance plus all other
accru ut unpal c arges 1mm late y an or to cancel your credit privileges under this Agreement because of:
(a) failure to make any payments in full when due under this Agreement;
(b} frequent overdrawing of your line of credit;
(c) failure to supply us with any information requested;
(d) supplying us with misleading, false, incomplete or incorrect information;
(e) breaking any of the promises, terms or conditions that are contained in this Agreement;
(f) the filing of a bankruptcy petition by or against you;
(g) the death of any borrower who signs this Agreement; or
(h) the sale or transfer of any interest in the property securing this agreement (this includes the creation of a
subordinate lien).
After default, you will pay our court costs, reasonable attorney fees (if attorney is not our salaried employee), and other
collection costs related to the default, if not prohibited by applicable law.
Any balance outstanding under this Agreement when the credit limit is terminated will continue to accrue interest at the
contract rate until paid n~full.
YOUR BILLING RIGHTS
KEEP THIS NOTICE FOR FUTURE USE
This notice contains important imformation about your rights and Lender's responsibilities under the Fair Credit Billing
Act.
Notify Lender In Case of Errors or Questions About Your Bill
If you think your bill is wrong, or if you need more information about a transaction on your bill, write Lender on a
separate sheet at the address listed on your bill after the words: "Send your billing error notice to: (Lender's, name and
address}." Write to Lender as soon as possible. Lender must hear from you no later than 60 days after Lender sent you the
first bill on which the error or problem appeared. You can telephone Lender, but doing so will not preserve your rights.
NOTICE: SEE THE FOLLOWING PAGE FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING
ERRORS.
11~I ~{ II~~ PA056363
F3NRE-00 II~~~YIIII~~~~~~HIII ~~~~~ ~~~~®IOfi~I~
^W151B252pgg5RLA8000PA0563530+~MWEAVER ~ ORIGINAL
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 4 of 4)
In your letter, give Lender the following information:
. Your name and account number.
• The dollar amount of the suspected error.
• Describe the error and explain, if you can, why you believe there is an error. If you need more information, describe the
item you are not sure about.
Your Rights and Lender's Responsibilities After Lender Receives Your Written Notice
Lender must acknowledge your letter within 30 days, unless Lender has corrected the error by then. Within 90 days, Lender
must either correct the error or explain why Lender believes the bill was correct.
After Lender receives your letter, Lender cannot try to collect any amount you question, or report you as delinquent.
Lender can continue to bill you for the amount you question, including finance charges, and Lender can apply any unpaid
amount against your credit limit. You do not have to pay any questioned amount while Lender is investigating, but you are
still obligated to pay the parts of your bill that are not in question.
I# Lender finds that Lender made a mistake on your bill, you will not have to pay any finance charges related to any
questioned amount. If Lender did not make a mistake, you may have to pay finance charges, and you will have to make up
any missed payments on the questioned amount. In either case, Lender will send you a statement of the amount you owe
and the date that it is due.
If you fail to pay the amount that Lender thinks you owe, Lender may report you as delinquent. However, if Lender's
explanation does not satisfy you and you .write to Lender within ten days telling Lender that you still refuse to pay, Lender
must tell anyone Lender reports you to that you have a question about your bill. And, Lender must tell you the name of
anyone Lender reported you to. Lender must tell anyone Lender reports you to that the matter has been settled between us
when it finally is.
If Lender doesn't follow these rules, Lender can't collect the first $SO of the questioned amount, even if your bill was
correct
Alternative Dispute Resolution and Other Riders: The terms of the Arbitration Agreement and any other Riders
slgne as part o t is own transaction are incorporat Into this Agreement by reference.
Applicable Law: The terms and conditions of this Agreement will be governed by the provisions of the Pennsylvania
onsumer iscount Company Act, Chapter 7, Sections 6201 through 6221, Purdon's Pennsylvania Statutes Annotated,
particularly Section 6217.1.
Before signing this Agreement, you have read and received this Agreement and the Federal Truth-In-Lending
disclosures contained in it.
You, the customer{s) signing below, agree to observe the terms and conditions of this Agreement.
This Agreement is entered under the applicable provisions of Federal law and the Pennsylvaaia Consumer
Discount Gom~any Act.
{SEAL)
tom Ignatu
(SEAL)
om ignature
Date: ~ - ~ 7 '' ~ ~/
Date: ~ - q " G
{SEAL} (SEAL)
Witness:
PaoSSSS+
RL F INRE ~I
(UIW~~~~WI~~u~119~~~~~~19~W11~I~~~~®~~I~~I
ryy1516252Ag85RLA8000PA0563640""WEAVER " ORIGINAL
(Page 1 of 1)
LOAN CLOSING STATEMENT
REVOLVING LOAN VOUCHER
CREDITOR
BENEFICIAL CONSUMER DISCOUNT COMPANY
4910 CARLISLE PIKE
SUITE ]04-HAMPDEN CENTER
MECHANICSBURG PA 17050
BORROWERS LOAN NO:
WEAVER, ILONKA C
WALKER, HELGA T
17 PINE HILL AVE
MECHANICSBURG PA 17050
Borrowers agree to and direct the disbursements and Advance indicated below. if any estimated amount shown below
varies from the actual amount paid, Borrowers agree to the disbursement of the actual amount and a corresponding
change to the Advance shown below. Borrowers agree that this Advance is made under Borrowers' Revolving Loan
Agrcement (account number shown above.}
.....................5 7807.43
T0: BENEFICIAL ACCOUNT # ?1171400554659 ................ 9 1748.00
PA STA EMPCU ..................................................................~ 370.00
FST PREMIER ...................................................................5 294.00
THE BON-TON ..................................................
................5 50.00
Initlel Annuel Fee ............................................ ...........5 732.57
CASH OR CHECK TO BORROWER ........................................••
...............# 11000.00
TOTAL ADVANCE(Sl ...............................................
WITNESS
BORROWERS: n ~ ~~~~
~D~a, ~~~: C~
gligla'-~
DATE
09-20-99 I~~~~~~1911~IU{N®~®I~I~~~f®U~®®~~IIIU~~~~IIU~~® PA137911
Rl Voucher ~ryy~5~g252A685RLY8000PA13791t0~MWEAYfR " ORIGINAL
VERIFICATION
P~.txicia L. l,~hes ;Recover Specialist for
BENEFICIAL OONS1Jl`'~[t DISCOUNT COM~'ANY
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 forgoing Complaint are true and
correct to the best of her knowledge, information and belief.
Patxicia L. lfughes
4
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SHERIFF'S RETURN - REGULAR
~_
CASE N0: 2007-04176 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
WEAVER ILONKA C ET AL
ROBERT BITNER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
WEAVER ILONKA C
was served upon
the
DEFENDANT at 1405:00 HOURS, on the 19th day of July 2007
at 17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
HELGA WALKER
MOTHER
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.60
Affidavit .00
Surcharge 10.00
.00
~'14~b1 ~ 37.60
Sworn and Subscibed to
before me this day
of ,
So Answers:
~J .~..~...t
R. Thomas Kline
07/20/2007
CHROMULAK & ASSOCIATES
By. ~~ ,
Deputy Sherif
A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2007-04176 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
WEAVER ILONKA C ET AL
ROBERT BITNER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
WALKER HELGA T the
DEFENDANT at 1405:00 HOURS, on the 19th day of July 2007
at 17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
HELGA WALKER
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 6 . 00 '~/~
Service .00
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
~ai~L'Q7 ~~], ~/ 16.00 07/20/2007
~"^ CHROMULAK & ASSOCIATES
Sworn and Subscibed to By:
before me this day eputy Sheri
of A.D.
.I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 07-4176 Civil Term
Plaintiff,
vs.
ILONKA C. WEAVER
and HELGA T. WALKER,
TYPE OF PLEADING:
Praecipe for Default Judgment
TYPE OF CASE:
Civil Action
Defendants.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, II. 60070
Defendants' Address:
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
Dated: AUGUST 23, 2007
FILED ON BEHALF OF:
BENEFICIAL CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQUIRE
PA ID N0.42067
MAUREEN A. DOWD, ESQUIRE
PA ID N0.90549
BETH ARNOLD HOWELL, ESQUIRE
PA ID N0.203606
CHRISTINE A. SAUNDERS, ESQUIRE
PA ID N0.203373
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND
~AN'Y INFORMATION
OBTAINED WILL BE USED
FOR THAT PURPOSE.
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4`~ Floor
Canonsburg, Pennsylvania 15317
(724) 916-2400
• ~.
TO: PROTHONOTARY
Please enter judgment by default against the within-named defendants, ILONKA C.
WEAVER and HELGA T. WALKER, for failure to file an Answer as follows:
Amount Claimed in Complaint: $20,387.83
Interest from 5/31/07 through 8/23/07: 865.69
Costs of Collection through 8/23/07:. 546.10
$21,799.62
Less Payment Received 8/10/07: -160.00
TOTAL $21,639.62
With interest accruing on the total balance of 21 639.62 at the rate of 6% per annum, together
with additional costs of suit.
BY ~ n i~~ ~ ~ Q Q
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 undersi ed authority, a Notary Public in and for said County and State,
personally appeared, fl ~d. ~~L~P~~ ,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 defendants on AUGUST 9, 2007 by certificate of mailing in accordance
with Pa.R.C.P. 237.1, as evidenced by the attached copy.
Sworn to an subscribed before me
This day of 2007.
Notary Public
~~~~~~~
CATHY ANN CHROMULAK, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
BETH ARNOLD HOWELL, ESQUIRE
CHRISTINE A. SAUNDERS, ESQUIRE
coNVV,Q nv~w~-
naanws«r
He~erl. HeRAakl, NoltiayP~bNc
oedi'rwp., waelit~on oour>gr
My Oarrnisabn 6~as,Ane 2&; 2014.
Member, Pennaylvenia Aee°datlon of Notaries
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND
ANY INFORMATION
OBTAINED WILL BE USED
FOR THAT PURPOSE.
C7
IN THE COURT OF COMMON PLEAS Off' CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION
Plaintiff,
Vs. No. 07-4176 CIVIL TERM
ILONKA C. WEAVER and
HELGA T. WALKER,
Defendants.
TO: ILONKA C. WEAVER
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
DATE OF NOTICE: AUGUST 9, 2007
IlVIPORTANT 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 M'ORTANT 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- 108
By: ~, ,
CATHY ANN C OMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevazd
4~ Floor
THIS IS AN ATTEMPT TO Canonsburg, PA 15317
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WII.L
T!L` TTCL'T L'AD TTIAT DTTDDACTi
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION
Plaintiff,
Vs. No. 07-4176 CIVIL TERM
ILONKA C. WEAVER :.nd
HELGA T. WALKER,
Defendants.
TO: HELGA T. WALKER
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
DATE OF NOTICE: AUGUST 4, 2007
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WR17lfiEN
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 WTTHIN 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
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR TART PURPOSE.
By; ~-+ ,
CATHY ANN ' OMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevazd
4`~ Floor
Canonsburg, PA 15317
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
No. 07-4176 -Civil Term
Plaintiff,
vs.
ILONKA C. WEAVER
and HELGA T. WALKER,
Defendants.
NOTICE OF ORDER DECREE OR JUDGMENT
TO: ILONKA C. WEAVER
1? PINE HILL AVENUE
MECHANICSBURG, PA 17050
(X~ Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above
captioned proceeding on g ~s o h
() A copy of the Order or Decree is enclosed, or
(~ The judgment is as follows: 21639.62 plus interest at the rate of 6% per
annum and additional costs of suit.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND
ANY INFORMATION
OBTAINED WILL BE USED
FOR THAT PURPOSE.
~ ~ ' ~
• ~. . r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
No. 07-4176 Civil Term
Plaintiff,
vs.
ILONKA C. WEAVER
and HELGA T. WALKER,
Defendants.
NOTICE OF ORDER DECREE OR 3UDGMENT
TO: HELGA T. WALKER
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
(X) Defendant
You are hereby notified that an Order Decree or Judgment was entered in the above
captioned proceeding on ^~ aB a7
() A copy of the Order or Decree is enclosed, or
(~ The judgment is as follows: 21 639.62 plus interest at the rate of 6% per
annum and additional costs of suit.
THIS tS AN ATTEMPT TO
COLLECT A DEBT AND
ANY INFORMATION
OBTAINED WILL BE USED
FOR THAT PURPOSE.
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAI~TIA
BENEFICLAL CONSTJ1vIER DISCOUNT
COMPANY,
Plaintiff,
vs.
ILONKA C. WEAVER
and HELGA T. WALKER,
Defendants,
CNII. DIVISION
No. 07-4176
TYPE OF PLEADING:
and
MEMBERS FIRST FEDERAL CREDIT
UNION,
Ga.~nishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, II., 60470
Defendants' Address:
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
Garnishee's Address:
1000 BRYN MAWR ROAD
CARLISLE, PA 17013
Date: December 27, 2007
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
PRAECIPE FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID N0.42067
MAUREEN A. DOWD, ESQ.
PA ID N0.90549
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO.203373
BETH ARNOLD HOWELL, ESQ.
PA ID N0.203606
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4~' Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY,
Plaintiff,
vs.
ILONKA C. WEAVER
and HELGA T. WALKER,
Defendants,
and
MEMBERS FIRST FEDERAL CREDIT UNION,
Garnishee.
CIVIL DIVISION
No. 07-4176
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 ILONKA C. WEAVER ,defendant, and
3. against HELGA T. WALKER,. defendant, and
4. against MEMBERS FIRST FEDERAL CREDIT UNION, garnishee,
5. and index this writ
a. against ILONKA C. WEAVER ,defendant, and
b. against HELGA T. WALKER, defendant, and
c. against MEMBERS FIRST FEDERAL CREDIT UNION, garnishee, and any
property of the defendant in the name of Garnishee:
Said Writ of Execution is pursuant to all monies due defendants in any accounts individual and
joint, personal and business.
6. Amount of Judgment $21,639.62
Additional Interest to Date $ 275.68
Less Payments $ 640.00
(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.
$21,275.30
CATHY ANN CffROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
CHRSTINE A. SAUNDERS, ESQ.
BETH ARNOLD HOWELL, ESQ.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4176 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 ILONKA C. WEAVER and HELGA T. WALKER, 17 Pine Hill Avenue, 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:
MEMBERS FIRST FEDERAL CREDIT UNION, 1000 Bryn Mawr Road, Carlisle, PA 17013
All monies due defendants 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 $20,999.62
L.L. $.50
Interest to Date - $275.68
Atty's Comm
Atty Paid $173.10
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 1/11/08
(Seal)
REQUESTING PARTY:
Name CHRISTINE A. SAUNDERS, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINT BOULEVARD, 4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Cart' R. Long, P otary
By:
Deputy
Supreme Court ID No. 203373
~ "'
IN'THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
' PENNSYLVANIA
-. ~-~FI'!/EfJ
BENEFICIAL CONSUMER DISCOUNT CIVIL DIVISION ,~, 2 ~ 2Q08
coMPANY,
Plaintiff, No. 07-4176
vs.
ILONKA C. WEAVER
and HELGA T. WALKER ~~
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
Defendants,
and
MEMBERS FIRST FEDERAL CREDIT UNION
Garnishee.
TO: MEMBERS FIRST FEDERAL CREDIT UNION
1000 BRYN MAWR ROAD
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.
Rau swfri.~ ~ 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 them on any negotiable or other written instrument, or did they
claim that you owed them any money or that you were liable to them for any reason:
RESPONSE: ~ ~ ~ ~ n Q
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 form a basis of the claim. 2
. ~ n ~ O r~ ~
RESPONSE. ~-
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
THIRD: At the tune you were served or at any subsequent hme, 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 Defendants? The
scope of this inte gatory encompasses, but is not restricted to, ntents of any hank
accounts}. r j 2~.~,() 3 ~ 51 b ~~ ~ ~ ~ 2 y' S ~}' I ~
~ ` ~~-v~ l,fatto6.b~
RESPONSE: ~ ~ Z ~ ~ `~ Z S ~- J'
~ ~~~~{~ G~~~n~ ~4. i3
C,J ~Gl'ill)
u~ r 5g
FOURTH: If your response to the previous interrogatory was anything other than an
unqualified neg identi the property, and in the case of tary assets, state the amount.
RESPONSE: SRV ~ I'~Q.S ~ ~ ~p.a
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 Defendants (or in which Defendants)
held or claimed interest. ~ ~ ~
n~
RESPONSE:
SIXTH: If your response to the previous interrogatory was anything other than an
unqualified negative, identify the property, and in the case of mo assets, state the amount.
RESPONSE: p n~ Z n a
SEVENTH: At the time you were served or at any subsequent time, did you hold as a fiduciary
any property in which the Defendants 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, ~ entify the property, and in the case of mo assets, state the amount.
RESPONSE: ~ ~ ~ 2
NINTH: At any time before or after you were served, did the Defendants 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 co eration therefore?
RESPONSE: ~ ~~
TENTH: 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 eree(s).
_ '1
RESPONSE: i ~ L~ 2 ~ ~
ELEVLNTbI: At any time after you were served, did you pay, transfei or-.deliver any money or
property of the Defendants or to any person or place pursuant to their direction or otherwise
discharge any cl ' of the Defendants against you?
RESPONSE: i ~~
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
.~ -`
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 trans and the name and address of the transferee(s).
RESPONSE:
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 fun n a recumng basis.
Z~- ~ ~
RESPONSE: ~~ ~ 7 ZS
~ Try-such -Je~1"
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 exemptio der 42 PaC.S. Section 8123? If so, identify account. ' ~ n ,
~ ~ ~U V v
RESPONSE: ~ u v'~
~~~
moo. o0 3pC~~ p~
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
DATE: ~a~'c~ ~ ~C~
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
~~
A
Cathy Ann Chromulak, Esq.
Maureen A. Dowd, Esq.
Christine A. Saunders, Esq.
Beth Arnold Howell, Esq.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY,
Plaintiff,
vs.
ILONKA C. WEAVER and
HELGA T. WALKER,
and
Defendant,
MEMBERS FIRST FEDERAL CREDIT
UNION,
Garnishee.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
CIVIL DIVISION:
No. 07-4176
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, E5Q.
PA ID NO.42067
BETH ARNOLD HOWELL, ESQ.
PA ID N0.203606
CHRISTINE A. SAUNDERS, ESQ.
PA ID N0.203373
TERESA K. GABRIEL, ESQ.
PA ID N0.205696
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
BENEFICIAL CONSUMER DISCOUNT
COMPANY,
Plaintiff,
vs.
ILONKA C. WEAVER and
HELGA T. WALKER,
Defendant,
and
MEMBERS FIRST FEDERAL CREDIT UNION,
Garnishee.
CIVIL DIVISION:
No. 07-4176
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO THE PROTHONOTARY:
Please discontinue this action against the above garnishee, MEMBERS FIRST
FEDERAL CREDIT UNION, and mark the docket accordingly.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Heather L Hatfield, Notary Public
t Cecil Twrp., Washington County
My Commission Expires June 29, 2010
'.9emher, Pennsylvania Association of Notarie.°
Sworn to and subscn ed
Before this day
of , 2008.
I,. Gii
Notary Pub ~c
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By: ~. 1
CATHY ANN CHROMULAK, 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 WELL
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 4TH day of FEBRUARY, 2008.
MEMBERS FIRST FEDERAL CREDIT UNION
C.O TANIA S. YOUNG
5000 LOUISE DRIVE, PO BOX 40
MECHANICSBURG, PA 17055
ILONKA C. WEAVER
HELGA T. WALKER
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
l`
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.
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` ~ SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-04176 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
WEAVER ILONKA C ET AL
And now STEVE BENDER ,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:10 Hours, on the 25th day of Januar 2008, attached
as herein commanded all goods, chattels, rights, d bts, credits, and
moneys of the within named DEFENDANT ,
WEAVER ILONKA C in the
hands, possession, or control of the within named arnishee
MEMBERS FIRST FEDERAL CREDIT UNION_ i,
1166 WALNUT BOTTOM RD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
MEG BEASTON (CUSTOMER SERVICE REP)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTIO and made
the contents there of known to Her
Sheriff's Costs: So answers;,,., 'i
Docketing .00 ~
~~ /~
~,./
Service . 0 0 -~«~-s ~ ~'`~"~ ~ ,,
,
~' ~ .~
Affidavit .00 R. Thomas Kli e
Surcharge .00 Sheriff of Cu erland County
.00
. 0 0
/ //.~o~d P ~,.,
01/28/2008
Sworn and Subscribed to
before me this day of By
A.D
Deputy Sheri f f
--• ._1 SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-04176 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
WEAVER ILONKA C ET AL
And now STEVE BENDER ,Sheriff or I
Cumberland County of Pennsylvania, who being duly
to law, at 0009:10 Hours, on the 25th day of Janua~
as herein commanded all goods, chattels, rights, dE
moneys of the within named DEFENDANT ,
WALKER HELGA T
uty Sheriff of
rn according
2008, attached
s, credits, and
in the
hands, possession, or control of the within named arnishee
MEMBERS FIRST FEDERAL CREDIT UNION
~~titi WALNUT BOTTOM RD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
MEG BEASTON (CUSTOMER SERVICE REP)
g
.00
. 0 0 / i ~30~ 0 8 ~..
01/28/2008
Sworn and Subscribed to
before me this day of By
Deput Sherif
A.D
with 3 true
y and made
p ~~~~~~
Affidavit .00 R. Thomas Kli e
Surchar e .00 Sheriff of Cu erland County
personally three copies of interogatories together
and attested copies of the within WRIT OF EXECUTIO
the contents there of known to Her .
Sheriff ' s Costs : So ai.~-~,szaer~:
a.:. ...
Docketing .00
Service .00 '
Sheriffs Office of Cumberland County
„f ~atrra~; Edward L Schorpp
R Thomas Kline ~~,,..~ ry~,~
Sheriff Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy _ _ Civil Process Sergeant
Beneficial Consumer Discount Company Case Number
vs. 2007-4176
Ilonka C Weaver
SHERIFF'S RETURN OF SERVICE
06/26/2009 10:55 AM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 26,
2009 at 1055 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant(s), to wit:, Ilonka C. Weaver and Helga T. Walker, in the hands,
possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut
Bottom Road, Carlisle, Cumberland County, Pennsylvania 17015, by handing to Marisol Barber, Assistant
Branch Manager, personally three copies of interrogatories together with three true and attested copies of
the writ of execution and made the contents there of known to her.
The writ of execution and notice to defendants was mailed on June 29, 2009, to Ilonka C. Weaver and
Helga T. Walker, both at 17 Pine Hill Avenue, Mechanicsburg, PA 17050.
2007-4176 So Answers,
Beneficial Consumer Discount Co. ~/~~ "
vs ``b~`~
Ilonka C. Weaver and R. ho ine, eri
Helga T. Walker
By
D puty Sheri f
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
vs.
ILONKA C. WEAVER
XXX-XX-5557
and HELGA T. WALKER
XXX-XX-1726
Plaintiff,
17 PINE HILL AVE.
MECHANICSBURG, PA 17050
Defendants,
and
MEMBERS FIRST FCU
Garnishee.
TO: MEMBERS FIRST FCU
1000 BRYN MAWR RD.
CARLISLE, PA 17013
CIVIL DIVISION
RECEIVEQ
JUN 2 62009
No. 07-4176 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 them on any negotiable or other written instrument, or did they
claim that you owed them any money or that you were liable to them for any reason:
RESPONSE:
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 /o}f; the claim.
RESPONSE: W
THIS tS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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 Defendants? The
scope of this interrogatory encompasses, but is not restricted to, the contents of any bank
account(s).
RESPONSE: G~~l.~-(~L~
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 Defendants (or in which Defendants)
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 Defendants had any interest?
RESPONSE:
THIS lS 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 Defendants 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, 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 Defendants onto any person or place pursuant to their direction or otherwise
discharge any claim of the Defendants against you?
RESPONSE: ~~
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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:
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 r~e~cu/rr~i~n/g~bas/is.
RESPONSE: G~~'~'~""""~"'
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: ~ ~ ~'~~
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.
Cathy Ann Chromulak, Esq.
Beth Arnold Howell, Esq.
Teresa K. Fuchs, Esq.
Jennifer M. Palonis, Esq.
401 Technology Drive
Suite 202
Canonsburg, PA 15317
(724) 916-2400
June 26, 2009
St
MEMBERS 1St
FEDERAL CREDIT UNION
Name: Ilonka C Weaver
Helga T Walker
Address: 17 Pine Hill Ave
Mechanicsburg, PA 17055
Account Number: XXX411
Name on Account:
Savings:
Checking:
Payroll-Social Security:
Helga T Walker
$1,231.14
25.00 Processing Fee
$1,206.14
$436.93
$1,134.00
All funds in the savings account are from Social Security and are exempt.
The checking account is attachable.
Account Number: XXX725
Name on Account: Ilonka C Weaver
Savings: $0.00
Checking: $7.72
Payroll: $817.93
Account Number: XXX333
Name on Account: Derek M Weaver
Ilonka C Weaver (Joint)
Savings: $81.50
$300.00 Statutory Exemption was not taken out.
Becky Mars all
Deposit Operations Analyst
5000 Louise Drive P.O. Box 40 Mechanicsburg, Pennsylvania 17055 (800) 283-2328 wwwmemberslst.org
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is Becky Marshall
(Name)
Deposit Operations Analyst ofMembers 1st Federal Credit Union
(Title)
(Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
(SIGN TU )
FlLE~--C~-f ; ~ c
OF THE ~~ ." ~TI-fr,<,,~~p,~y
Z~a~ ~~€. -2 ~~ ~ ~ : ~ ~
Ci't.~~d`r - . ~ ""
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY,
Plaintiff,
VS.
ILONKA C. WEAVER and HELGA T.
WALKER,
Defendant,
AND
i
MEMBERS 1ST FEDERAL CREDIT
UNION,
Garnishee.
J
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
,,
;.
CIVIL DIVISION
No. 07-4176 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.
P ID NO.42067
~TH ARNOLD HOWELL, ESQ.
PA ID NO.203606
TERESA K. FUCHS, ESQ.
PA ID N0.205696
JENNIFER M. PALONIS, ESQ.
PA ID N0.205703
CHROMULAK & ASSOCIATES, L.L.C.
401 Technology Drive
Suite 202
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.
ILONKA C. WEAVER and HELGA T.
WALKER,
Defendant,
and
MEMBERS 1ST FEDERAL CREDIT UNION,
Garnishee.
CIVIL DIVISION
No. 07-4176 CIVIL TERM
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
Please discontinue this action against the above garnishee, MEMBERS 1ST FEDERAL
1
CREDIT UNION, and mark the docket accordingly.
COMMONWEALTH OF PENNSYLVAiti~.'1
__._ -.do•~riafSeal..~
Heather L, i •tfiel~, Notary Public
G:cil Twp.: Vastiinc;ton Couniy
?v1y ~.ommissi, :Expires :+.rne 29, 2010
~fCPS;JEi, ?sr.ns~l~~~n~a A.s.caa°.~cr~ of voiasi:~
Sworn to and subsc 'bed
Before me this ~`~- day
of , 2009.
V _ wl~
~Y~~
Notary Pub is
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By:1~e;~1.~.~~1-~~
CATHY ANN CHROMULAK, ESQUIRE
BETH ARNOLD HOWELL, ESQUIRE
TERESA K. FUCHS, ESQUIRE
JENNIFER M. PALONIS, ESQUIRE
Attorneys for Plaintiff
401 Technology Drive
Suite 202
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 BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true
and correct copy of the foregoing Praecipe to Discontinue Aga//inmo~st Garnishee Only was served
upon the following by First Class Mail, postage prepaid on this ~L! ~ day of4. , 2009.
~~,~c~/'
MEMBERS 1ST FEDERAL CREDIT UNION
5000 LOUISE DRIVE, PO BOX 40
MECHANICSBURG, PA 17055
ILONKA C. WEAVER and HELGA T. WALKER
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
~~~~~
Cathy Ann Chromulak, Esq.
Beth Arnold Howell, Esq.
Teresa K. Fuchs, Esq.
Jennifer M. Palonis, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
F1LEG--a~r~iC
2Q09 J~a -~ ~'~ 2~ 3 7
,,;
cur, ~ .,.:yp~
r, -~
t_. 'v k i''. iP ~ ~
$8. oo P ~ STN
c~~~a'1
p~ aa~`15o
Beneficial Consumer Discount
Vs
Ilonka C. Weaver
Writ of Execution
Docket No. 2007-4176 Civil Term
~~C T~_'r E t~n.T~
2~0~ ~'Q~ i b F` f
C.f'~, ' } F ~,
r i:`
,,: °:
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED. No action has been taken in the last six months.
Sheriff s Costs
Docketing $18.00
Surcharge $40.00
Levy $20.00
Mileage $ 4.80
Poundage $ 1.89
Prothonotary $ 2.50
Garnishee $ 9.00
Total $96.19 / ///~.e/o9 `-~,,.
So Answers:
~~~~
R. Thomas Kline, Sheriff
~' ..._ ..
BY E~ ..
Serge t
Cts
~.~ ~~
j V
C:~2 ~~ pct r7
D ~ ~3~i~z
r' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
vs.
ILONKA C. WEAVER
and HELGA T. WALKER,
and
MEMBERS FIIZST FCU,
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Plaintiff,
Defendants,
Garnishee.
Defendants' Address:
17 PINE HILL AVE.
MECHANICSBURG, PA 17050
Garnishee's Address:
1000 BRYN MAWR RD.
CARLISLE, PA 17013
Date: 3ANUARY 14, 2010
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CIVIL DIVISION
No. 07-4176 CIVII, TERM
TYPE OF PLEADING:
PRAECII'E FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
BENEFICIAL CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID N0.42067
SETH ARNOLD HOWELL, ESQ.
PA ID NO.203606
TERESA K. FUCHS, ESQ.
PA ID N0.205696
JENNIFER M. PALONIS, ESQ.
PA ID N0.205703
CHROMULAK & ASSOCIATES, L.L.C.
401 Technology Drive
Suite 202
Canonsburg, PA 15317
(724) 916-2400
t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 07-4176 CIVIL TERM
Plaintiff,
vs.
ILONKA C. WEAVER 17 pine N-ill Ate, Mechwnicsbu~g PA 1'1050
and HELGA T. WALKER,
Defendants,
and
MEMBERS FIRST FCU,
loon Bryn r/tp~,wr ~+.ol
Carlisle PA 17013 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 1LONKA C. WEAVER, defendant, and
3. against HELGA T. WALKER, defendant, and
4. against MEMBERS FIRST FCU, garnishee,
5. and index this writ
a. against ILONKA C. WEAVER, defendant, and
b. against HELGA T. WALKER, defendant, and
c. against MEMBERS FIRST FCU, 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
joint, personal and business.
6. Amount of Judgment
Additional Interest to Date
(Costs to be added)
Less
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.
$21,639.62
$ 2,338.98
$10,321.15
$13,657.45
~y~1~
CATHY ANN CHROMULAK, ESQ.
BETH ARNOLD HOWELL, ESQ.
TERESA K. FUCHS, ESQ.
3ENNIFER M. PALONIS, ESQ.
F~
n,
'~
t' f ~ ~i~.,JL
zoto ~~~~a ~ ~~t~~ tio~
;;.,
c~~. ~: _ :, ~~
~' _ 'e '.
~a+}. so P1~ A-n-y
37•!v0 C,BF
Ilo. oo ~~
Q(o.Iq '~
'T ~ . 50 "
I'~. oo "
011.50 ~~
8.00 «
d4. so ~~
8. o~ "
331. ?9 - P~ r,`rt~/
$a.oo Due co
c~~ 11 Lo4~
P,~ oZ 3~o N'70
lt~rit oP
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA}
COUNTY OF CUMBERLAND)
NO 07-4176 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 ILONKA C. WEAVER and HELGA T. WALKER, 17 Pine Hill Ave, 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:
MEMBERS FIRST FCU, 1000 Bryn Mawr Road, Carlisle, PA 17013
All monies due defendant
s 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 $11,318.47 L.L.
Interest to Date -- $2,338.98
Atty's Comm °l° Due Prothy $2.00
Atty Paid $331.79 Other Costs
Plaintiff Paid
Date: l /20/l 0
David D. Buell, Prothonot
(~;eal) By:
Deputy
REQUESTING PARTY:
Name BETH ARNOLD HOWELL, ESQUIRE
Address: CHROMULAK & ASSOCIATES, LLC
401 TECHNOLOGY DRIVE, SUITE 202
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203606.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~ ;~
..~
Ronny RAnderson -- ~ ~,^ ~-- _ - -r-,
-, ; ~; r-, ; , ~ tom-
Sheriff .. _~,~r~
~4`,y,,, of ~":r,+r,G,~rf~~d ~ ` ,~
Jody S Smith
Chief Deputy - _
Edward L Schorpp _ ~ ~ `~~
Solicitor ~~~ .:~ ~_ ~- ~.~: °::
c,~ n
Beneficial Consumer Discount Company Case Number
vs.
Ilonka C Weaver 2007-4176
SHERIFF'S RETURN OF SERVICE
01/26/2010 04:09 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on January
26, 2010 at 1610 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendants, to wit: Ilonka C. Weaver and Helga T. Walker, in the hands,
possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut
Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Marisol Barber, Assistant
Branch Manager personally three copies of interrogatories together with three true and attested copies of
the writ of execution and made the contents there of known to her.
The writ of execution and notice to defendants were mailed on January 27, 20 t Helga T. Walker at 17
Pine Hill Avenue, Mechanicsburg, PA 17050; and to Ilonka C. Weaver~n ne ill Avenue,
Mechanicsburg, PA 17050.
January 27, 2010
SO ANSWERS,
R R ANDERSON, SHERIFF
ici Coun?ySuitc Sheriff, i~e~eas~ `t. Ind.
'>
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -
BENEFICIAL CONSUMER .. CIVIL DIVISION - R ~ G E.I V E D
DISCOU3~TT COMPANY, ~ ~ - JAN 2 6 [ u ~~ u
Plaintiff, No. 07-4176 CIVIL' TERM '
vs.
ILONKA C. WEAVER • •
x:XX-XX-5557
and HELGA T. WALKER ~ .
XXX-XX-1726
17 PINE HILL AVE.
• 1VIECHANICSBURG, PA 17050 C-, r,,
Defendants, ~-~~ ~~;
-'' _~
m
and e~ ~~,
~~
- ' ~ Lr
MEMBERS FIRST FCU ~` ~'- -~, ~' `-
Garnishee. • . "„ ' -
~~ ..> r`
.,
TO: MEMBERS FIRST FCU '-' ~':' ~~-'
1000 BRYN MAWR RD.
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.
J~,us~,c~p1LS ~ 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 them on any negotiable or other written instrument, or did they
claim that you owed them any money or that you were liable to them for any reason:
RESPONSE: ,~
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: G~~ '
- ,
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
- THIlZD: 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 Defendants? The . .
scope of this interrogatory encompasses, but is'not restricted to, the contents of any bank . -
aecount(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 Defendants (or in which Defendants)
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 Defendants 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 Defendants 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, 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).
ELEVENTH: At any time after you were served, did you pay, transfer or deliver any money or
property of the Defendants or to any person or place pursuant to their direction or otherwise
discharge any claim of the Defendants against you?
RESPONSE: C~~.u~
~~~
RESPONSE:
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
. '.
TWELFTH: ~ If your response to the previous interrogatory was anythYng 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 addres$ of the transferee(s). ~ ~ ~ ',
RESPONSE:
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: C~~~~ ~~~
DATE: v~ ~~~ ~~~
THIS 1S AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
ari~,.e,~ ~~~
Cathy Ann Chromulak, Esq
Beth Arnold Howell, Esq.
Teresa K. Fuchs, Esq.
Jennifer M. Palonis, Esq.
401 Technology Drive .
Suite 202
Canonsburg, PA 15317
(724) 916-2400
.,
MEMBERS 1St
FEDERAL CREDIT CiNION
January 26, 2010
Name: Ilonka C Weaver
Helga T Walker
Address: 17 Pine Hill Ave
Mechanicsburg, PA 17055
Account Number: XXX411
Name on Account: Helga T Walker
Savings: $70.66
25.00 Processing Fee
$45.66
Checking: $672.10
Payroll-Social Security
All funds in this account are from Social Security and are exempt.
Account Number: XXX725
Name on Account:
Savings:
Checking:
Payroll-PA Treasury
Account Number: XXX333
Name on Account:
Savings:
Ilonka C Weaver
$0.00
$10.50
Derek M Weaver
Ilonka C Weaver (Joint)
$119.18
$300.00 Statutory Exemption was not taken out.
Tania S. Young
-- d ,
5000 Louise Drive P.O. Box 40 Mechanicsburg, Pennsylvania 17055 (800) 283-2328 wwwmemberslst.org
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is Tania S. Young
(Name)
Deposit Operations AnalystofMembers 1st Federal Credit Union
(Title)
(Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
(SIGNA RE)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY,
Plaintiff,
vs.
ILONKA C. WEAVER AND HELGA T.
WALKER,
Defendant(s),
and
MEMBERS FIRST FCU,
Garnishee
CIVIL DIVISION:
No. 07-4176 CIVIL TERM
TYPE OF PLEADING:
Praecipe to Settle & Discontinue
Against Garnishee ONLY
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
BENEFICIAL CONSUMER DISCOUNT
COMPANY
COUNSEL OF RECORD:
~~
a:~
ch
s
cs.
S
1
m
e~
0
0
~.+
:~~~'
-~" ~ .
C ~c~ /!48 ~
l2-~- a.3 ~as~
CATHY ANN CHROMULAK, ESQ.
PA ID N0.42067
BETH ARNOLD HOWELL, ESQ.
PA ID NO.203606
TERESA K. FUCHS, ESQ.
PA ID NO.205696
JENNIFER M. PALONIS, ESQ.
PA ID NO. 205703
CHROMULAK & ASSOCIATES, L.L.C.
401 Technology Drive, Suite 202
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.
CIVIL DIVISION:
No. 07-4176 CIVIL TERM
ILONKA C. WEAVER AND HELGA T.
WALKER,
Defendant(s),
and
MEMBERS FIRST FCU,
Garnishee.
PRAECIPE TO SETTLE & DISCONTINUE AGAINST GARNISHEE ONLY
TO THE PROTHONOTARY:
Please settle & discontinue this action against the above garnishee, MEMBERS FIRST
FCU, and mark the docket accordingly.
Sworn to and subscribed
Before e this ~~ day
of rx , 2010.
Notary
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
n~ (/_ ,
CATHY ANN CHROMULAK, ESQ.
BETH ARNOLD HOWELL, ESQ.
TERESA K. FUCHS, ESQ.
JENNIFER M. PALONIS, ESQ.
Attorneys for Plaintiff
401 Technology Drive, Suite 202
Canonsburg, PA 15317
Notarial Seal
Heather L. Hatfield, Notary Public
Cecil Twp., Washington County
(Uty Commission E~ires June 29, 2010
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Member, Pennsylvania Association of Notaries
CERTIFICATE OF SERVICE
I, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true
and correct copy of the foregoing Praecipe to Settle & Discontinue Against Garnishee Only was
served upon the following by First Class Mail, postage prepaid on this 2ND day of FEBRUARY
2010.
MEMBERS FIRST FCU
1000 BRYN MAWR ROAD
CARLISLE, PA 17013
ILONKA C. WEAVER
HELGA T. WALKER
17 PINE HILL AVENUE
MECHANICSBURG, PA 17050
Cathy Ann Chromulak, Esq.
Beth Arnold Howell, Esq.
Teresa K. Fuchs, Esq.
Jennifer M. Palonis, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Y
'~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ~.~}"~~~
Sheriff '' 11~ ~h/'*'",,.,_(~i~~T/`1F i ~
~~~„tr at ~un~br~.f~~~
Jody S Smith
chief Deputy ;~~ ~~x~ ° 10 AUG 3 I aM 8'• ~ ~
};:,
Richard W Stewart ~` ~""
Solicitor ~t~~ of -~~ s~~~trj= CUM3EFi1.A~ ..~; ~.~(~~
pp~1SYLVAwA
Beneficial Consumer Discount Company Case Number
vs. 2007-4176
Ilonka C Weaver (et al.)
SHERIFF'S RETURN OF SERVICE
06/26/2009 10:55 AM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 26,
2009 at 1055 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and movie:
of the within named defendant(s), to wit:, Ilonka C. Weaver and Helga T. Walker, in the hands,
possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut
Bottom Road, Carlisle, Cumberland County, Pennsylvania 17015, by handing to Marisol Barber, Assistant
Branch Manager, personally three copies of interrogatories together with three true and attested copies of
the writ of execution and made the contents there of known to her.
The writ of execution and notice to defendants was mailed on June 29, 2009, to Ilonka C. Weaver and
Helga T. Walker, both at 17 Pine Hill Avenue, Mechanicsburg, PA 17050.
08/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $96.74
August 30, 2010
SO ANSWERS,
~~-~"~.
RON R ANDERSON, SHERIFF
By
haron R. Lantz
P~ a~~~~/
(cj GountySuite Sheriff, Teleosoft, Inc.
~ ~~
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ~'ll.~l}-t~}"F~ "
Sheriff ~~sV
$u~Sr 4f +Elripbtr~ ~ ~ ~~`''r`-r j~ll~Tiv'ZI
Jody S Smith ~ ~~
Chief Deputy '~ ~ ~- ~ ~ f~ 10 AU6 3 I AM 8= 2 8
Richard W Stewart
SOIICIt'Or GFFi~:E OF T~,r S~ER~FF ~~~i~p~~~i~r~...,~;~,ju AAtA~~~AAU1~1
~"G`fI W7' L.VN~1
Beneficial Consumer Discount Company
vs. Case Number
Ilonka C Weaver (et al.) 2007-4176
SHERIFF'S RETURN OF SERVICE
01/26/2010 04:09 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on
January 26, 2010 at 1610 hours, attached as herein commanded all goods, chattels, rights, debts, credits,
and monies of the within named defendants, to wit: Ilonka C. Weaver and Helga T. Walker, in the hands,
possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut
Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Marisol Barber, Assistant
Branch Manager personally three copies of interrogatories together with three true and attested copies of
the writ of execution and made the contents there of known to her.
The writ of execution and notice to defendants were mailed on January 27, 2010 to Helga T. Walker at 17
Pine Hill Avenue, Mechanicsburg, PA 17050; and to Ilonka C. Weaver at 17 Pine Hill Avenue,
Mechanicsburg, PA 17050.
08/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $96.29
August 30, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
B
aron R. Lantz
~ ~~~a~
~ ~y~~~/
(cj CountySuite Sheriff. Teleosoft. Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Beneficial Consumer Discount Company, CIVIL DIVISION
lug
Plaintiff,
Case No. 07-4176 Civil Term -
?c
vs.
TYPE OF PLEADING:
Ilonka C. Weaver and Helga T. Walker,
t
Praecipa to Satisfy Judgment
?° •• '
; 7,
Defendant(s).
TYPE OF CASE:
Civil Action
e
Plaintiff's Address:
368 Seahawk Circle FILED ON BEHALF OF:
Virginia Beach 23453
Beneficial Consumer Discount Company
COUNSEL OF RECORD:
CATHY ANN CHROMULAI ESQ.
Date: May 31, 2012 PA ID NO. 42067
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
NATHAN A. MORGAN, ESQ.
PA ID NO. 202885
CHROMULAK & ASSOCIATES, L.L.C.
401 Technology Drive, Suite 202
Canonsburg, PA 15317
(724) 916-2400
s
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FORTHAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Beneficial Consumer Discount Company,
vs.
Plaintiff,
Ilonka C. Weaver and Helga T. Walker,
,
M
Defendant(s).
CIVIL DIVISION
Case No. 07-4176 Civil Term
PRAECIPE TO SATISFY JUDGMENT
i
To the Prothonotary:
Please satisfy the judgment against Ilonka C. Weaver and Helga T. Walker, at No.
07-4176 Civil Term, and mark the docket accordingly.
Respectfully submitted,
CHROMULAK & A SOCIATES, L.L.C.
By: -
CATHYIANN Cl
PA ID NO. 42067
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
NATHAN A. MORGAN, ESQ.
PA ID NO. 202885
Counsel for Plaintiff
401 Technology Drive, Suite 202
Canonsburg, PA 15317
Sworn to and subscrrib d
Before me this -- M, -day
of '20 2Z .
Notary Pub 'c
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Heather L. Hatfield, Notary Public
Cecil Twp., Washington County
My commission Expires June 29, 2014
Member. Pennsvivania Association 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 Satisfy Judgment was served upon the following by
First Class Mail, postage prepaid on this 31 st day of May, 2012:
Ilonka C. Weaver
Helga T. Walker
17 Pine Hill Avenue
Mechanicsburg PA 17050
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
.Beth Arnold Howell, Esq.
Nathan A. Morgan, Esq.
Chromulak & Associates, L.L.C.
401 Technology Drive, Suite 202
Canonsburg, PA 15317