HomeMy WebLinkAbout07-4329
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
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY CIVIL DIVISION
Plaintiff,
Vs. No. Q~f - ~1.3n'~
BRENDA L. EHLMAN
Defendant(s)
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT.
C~iv~ 1 1 em'-
If you wish to defend against the claims set forth in the following pages, you must
take action within twenty (20) days after this complaint and notice are served, by
entering a written appearance personally or by attorney and filing in writing with
the court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment
may be entered against you by the court without further notice for any money
claimed in the complaint or for any other claim or relief requested by the plaintiff.
You may lose money or property or other rights important to you. YOU
SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 07- ~/3.~9 ~ .~..."
Plaintiff,
vs.
BRENDA L. EHLMAN,
Defendant.
PlaintifFs Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
94 ASHFORD DRIVE
ENOLA, PA 17025-2331
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:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID N0.42067
MAUREEN A. DOWD, ESQ.
PA ID NO.90549
BETH ARNOLD HOWELL, ESQ.
PA ID N0.203606
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
HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
No.
Plaintiff,
vs.
BRENDA L. EHLMAN,
Defendant.
COMPLAINT
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. BRENDA L. EHLMAN is an adult individual residing at 94 ASHFORD DRIVE,
ENOLA, PA 17025-2331.
3. On or about APRIL 14, 2005, 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.
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 MARCH 30, 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 ofNINE-THOUSAND TWO-HUNDRED
FIFTY-NINE and 33/100 ($9,259.33) DOLLARS as of JUNE 13, 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 ofNINE-THOUSAND TWO-
HUNDRED FIFTH-NINE and 33/100 ($9,259.33) DOLLARS, with interest thereon at the rate
of 18.36% from JUNE 14, 2007, plus court costs and attorney's fees.
Respectfully submitted,
Chromulak & Associates, LLC
CATHY ANN CHROMULAK, ESQ.
PA ID N0.42067
MAUREEN A. DOWD, ESQ.
PA ID N0.90549
BETH ARNOLD HOWELL, ESQ.
PA ID N0.203606
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
-: Attorneys for Plaintiff
375 Southpointe Boulevard
THIS IS AN ATTEMPT t0 4tn Floor
COLLECT A DEBT AND ANY Canonsburg, PA 15317
INFORMATION OBTAINEQ~WILL
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 SQUARElSUITE 107
MECHANICSBURG PA 17055
BORROWERS (called "You", "Your") LOAN NO:
EHLMAN, BRENDA L
SS#
94 ASHFORD DRIVE
ENOLA PA 17025
REQUIRED INSURANCE. You moat obtain insurance for term of loan covering security for this loan as indicated below,
naming us ns Loss Payee:
Title insurance on teal ostate security.
Fire end extended wverage insurnnce oa real estate security.
Physical dnmage insurance on vehicle listod under "Security" above iP "Y" appears under "Insured".
Physical dnmage iasurnnco on other property listed under "Security" above if "Y" appears under "Insured".
You may obtain any required insurance from anyone you choose.
(Sae "Socurity" paragraph above fo insured.)
NOTICE: THE FOLLOWING EXHIBIT TIONAL CONTRACT TERMS.
05-01-04 NRE IIII~~~~~~~®~ '" `~ ~~~~~~(~~~ PA875011
'~E546157B9N99CEA9000PAB750210K 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.
DATE ON WHICH FINANCE CHARGE BEGINS. Finance Charges begin on the date of disbursement. If this loan is
made by marl, the date an which the Finance Charge begins is postponed by the number of days from the date of this
Agrecrnent to the date of disbursement. Payment due dates and effective date of any optional insurance purchased are also
postponed.
PAYOUTS. Yau agree to pay-outs of Amount Financed as shown on Truth-In-Lending 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 owe will be reduced by unearned Finance
Charge (but not Service Charge) determined by the "Rule of 78ths".
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 an page one, which will secure all
indebtedness, including future advances under this Agreement.
LATE CHARGE. If you don't pay any payment in l0 days after it's due, you will also pay 1 112 per month on the
amount overdue (subject to a $1.OQ minimum charge}.
BAD CHECK CHARGE. We will charge you a fee of $ZO 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 required insurance in force, (a) all your
payments may became 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, fvr 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 RESOLUTION AND OTHER RIDERS. The terms of the Arbitration Agrcement and any
other Riders signer as part of this loan transaction are incorporated into this Agreement by reference.
APPLICABLE LAW. The Pennsylvania Consumer Discount Company Act (COCA), Title 7, Pardon's Pennsylvania
Statutes, governs this loan.
NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS.
o5-as-oa NRE
PA87562T
"E54Bi5789N99CEA9000PAB750220"xEHL1A/W " 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.
BO ROWERS:
(SEAL)
(SEAL)
{SEAL)
WITNES .
y
05-01-04 NRE PAB75023
I~~~I~~~~~I~I~~~f~®~~N~~~~~~~~~I~
~E54815789N99CEA9000PA8T50230~xEHLAUW ~ OR16lNAL
TRUTH-IN-LENDING DISCLOSURES (Page l of 2)
LENDER (Celled "We", "Our", "Us")
HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY
25 GATEWAY DRIVE
GATEWAY SOUAREISUITE 107
MECHANICSBURG PA 17055
BORROWERS (Called "You", "Your") LOAN NO:
EHLMAN, BRENDA L
94 ASHFORD DRIVE
ENOIA PA 17025
.ANNUAL
PERCENTAGE
RATE
. FINANCE
CHARGE
The dollar smouat
the credit will cost
you.
Amount
Financed
Tha smouat of cn
provided to you or
your behalf.
f otaI of Payment
The amount you wi]
have paid after you
bare made nll pey-
meats as scheduled.
Date
of
Loan
The cost of your credit
as a yearly rate.
26.713X : 6088.68 $ 7408.32
~_ _L~,..~_ :,, ~.
s 13497.00
04114!05
Number of Pa meats Amount of Pa meats When Pn meats Are Due
1 S 224.95 05!14!05
059 s 224.95 Day 14 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 $1.00 minimum charge},
Prepayment: If you pay off early, you may be entitled to a refund of part of the Finance Charge.
See the contract documents for any additional information about nonpayment, default, any required repayment
in full before the scheduled date, and prepayment refunds.
NOTICE: The following pages} contain(s) additional information.
DB-14-04 NSE TIL
lll~~®I~~~~~~I~IIN~~1~~N~1111~
~E54B15789N99FED4000PAB1812t0""EHLMMI "
PAB18121
~Illlllall~l~~
OR I G I IdAL
TRUTH-IN-LENDING DISCLOSURES (Page 2 of 2}
ITEMIZATION OF THE AMOUNT FINANCED
T0. BRENDA L EHLMAN{FIMC,HOME ~ AUTO SECURITY) ................................t 599.95
CREDIT LIFE INSURANCE {PAID TO INSURANCE COMPANY) .............................5 293.56
CREDIT DISABILITY INSURANCE {PAID TO INSURANCE COMPANY) .......................5 580.37
CREDIT INVOLUNTARY UNEMPLOYMENT INSURANCE (PAID TO INSURANCE COMPANY).........5 534.48
CASH OR CHECK TO BORROWER .....................................................5 5399.96
loan Fee .................................................s 150.00
PREPAID FINANCE CHARGES {TOTAL)....•••.•••••••••••••••••••••••••••••••••••••••$ 150.00
AMOUNT FINANCED {EXCLUDING PREPAID FINANCE CHARGE) ............................5 7408.32
68-14-04 NRE TIL
PA818122
~E54B15769N99FE09DOOPAB191220~~EHLAVW ~ ORIGINAL
VElt1FIGATI4N
DIANNA WIGGINS ,Recover Specialist for
rniS hold F' ce Ccm~aner Discaant Campany
Deposes and says subject to the penalties of 28 Pa C.S. Section 4904 relating to unsworn
falsercation to authorities, that the facts set forth in the forgoing Complaint are true and
con-ect to the best of her knowledge, infon~nation and belief
~y
DIANNA WIGGINS
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SHERIFF'S RETURN - REGULAR
CASE N0: 2007-04329 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
EHLMAN BRENDA L
VALERIE WEARY
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
EHLMAN BRENDA L
the
was served upon
DEFENDANT
at 1655:00 HOURS, on the 2nd day of August 2007
at 94 ASHFORD DRIVE
ENOLA, PA 17025-2331
BRENDA L EHLMAN
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 14.40
Affidavit .00
Surcharge 10.00
.00
~ll'7I~}~ `~~ 42 .40
Sworn and Subscibed to
before me this day
So Answers:
/~
~ .~
. ~ •--'~'°`s'~ ,i'ce`
R. Thomas Kline
08/06/2007
CHROMULAK & ASSOCIATES
By:
Deputy Sheri f
of A.D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 07-4329 CIVIL TERM
Plaintiff,
vs.
BRENDA L. EHLMAN,
Defendant.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
94 ASHFORD DRIVE
ENOLA, PA 17025-2331
Dated: SEPTEMBER 10, 2007
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND
ANY INFORMATION
OBTAINED WILL SE USED
FOR THAT PURPOSE.
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 CIiROMULAK, 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
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
r
TO: PROTHONOTARY
Please enter judgment by default against the within-named defendant, BRENDA L.
EHLMAN, for failure to file an Answer as follows:
Amount Claimed in Complaint: $ 9,259.33
Interest from 6/14/07 through 9/10/07: 420.08
Costs of Collection through 9/10/07: 534.90
TOTAL $10,214.31
With interest accruing on the total balance of 10$ ,214.31 at the rate of 6% per annum, together
with additional costs of suit.
7
BY (~ ` _
CATHY ANN CHROMULAK, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
BETH ARNOLD HOWELL, ESQUIRE
CHRISTINE A. SAUNDERS, ESQUIRE
Attorneys for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATION OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF WASHINGTON
Before me, the dersigned authority, a Notary Public in and for said County and State,
personally appeared, ~,1~(ISfiYIe 17~ ~'{.l.tilG~~t'S ,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 AUGUST 23, 2007 by certificate of mailing in accordance
with Pa.R.C.P. 237.1, as evidenced by the attached copy.
CATHY ANN OMULAK, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
BETH ARNOLD HOWELL, ESQUIItE
CHRISTINE A. SAUNDERS, ESQUIRE
Sworn to and subscribed before me
This day of , 2007.
~ ~~
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial seal
lieatltertw FlatAeld, Notary Pubiic
Cedl Twp., Wad ,
~ Corrxrri~brt E>g7ires June 29, x010
Membsr, Pennsylvania Aseodatlon of NotarieR
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 CIVIL DIVISION
DISCOUNT COMPANY,
Plaintiff, No. 07-4329 CIVIL TERM
Vs.
BRENDA L. EHLMAN,
Defendant(s).
TO: BRENDA L. EHLMAN
94 ASHFORD DRIVE
ENOLA, PA 17025-2331
DATE OF NOTICE: AUGUST 23, 2007
IlVIPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII.ED 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~ / t ~~~CJI~ _ ~ t1eJLJ~
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CATHY ANN CHROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4~' 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. 07-4329 CIVIL TERM
Plaintiff,
vs.
BRENDA L. EHLMAN,
Defendant.
NOTICE OF ORDER DECREE OR JUDGMENT
TO: BRENDA L. EHLMAN
94 ASHFORD DRIVE
ENOLA, PA 17025-2331
(X) Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above
captioned proceeding on 9 la o7
() A copy of the Order or Decree is enclosed, or
(X) The judgment is as follows: $10,214.31 ulus interest at the rate of 6% per
annum and additional costs of suit.
n~
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 CIVIL DIVISION
DISCOUNT COMPANY
vs.
BRENDA L. EHLMAN
and
SOVEREIGN BANK
and
M&TBANK
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
94 ASHFORD DRIVE
ENOLA, PA 17025-2331
Date: September 27, 2007
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Plaintiff,
No. 07-4329 CIVIL TERM
~=~ c~
~ .F
TYPE OF PLEADING: f
~ -~-~
PRAECIPE FOR A WRIT OF ~ ' ,- tv
Defendant,
EXECUTION __
FILED ON BEHALF OF:
Garnishee, HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
Garnishee.
CATHY ANN CHROMULAK, ESQ.
PA ID N0.42067
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
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Ilv THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff,
vs.
BRENDA L. EHLMAN
and
SOVEREIGN BANK
Defendant,
Garnishee,
CIVIL DIVISION
NO. 07-4329 CIVIL TERM
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 BRENDA L. EHLMAN, defendant, and, a7oo Sanders f?d, ~rospac(- peio~{.1s,2'L bo~7~
3. against SOVEREIGN BANK, garnishee, and , i~ w. HIGH sT, CnQ~lSt,c pq I7o~3
4. against M & T BANK, garnishee , I w. HiGN sr, eAeus~e, aA no,3
5. and index this writ
a. against BRENDA L. EHLMAN, defendant, and
b. against SOVEREIGN BANK, garnishee, and any property of the defendant in the
name of Garnishee, and
c. 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.
6. 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.
$10,214.31
$ 2s.so
$10,239.81
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 07-4329 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 BRENDA L. EHLMAN, 2700 SANDERS RD., PROSPECT HEIGHTS, IL 60070
(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 SOVEREIGN BANK, GARNISHEE, 17 W. HIGH ST., CARLISLE, PA 17013 AND M & T
BANK, GARNISHEE, 1 W. HIGH ST., CARLISLE, PA 17013 -- PURSUANT TO ALL MONIES
DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND
BUSINESS.
GARNISHEE(S) as follows:
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 $10, 214.31
Interest $25.50
Atty's Comm
Atty Paid $162.40
Plaintiff Paid
Date: OCTOBER 2, 2007
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
is R. Long, ProthonotaryGyy
`By: o / /~L/1A./l~~
Deputy
REQUESTING PARTY:
Name CHRISTINE A. SAUNDERS, ESQ.
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD
4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203373
-~.
IN THE COURT OF COMMON PL + AS OF CUMBERLAND COUNTY,
PENNSYLVANIA
M
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff,
vs.
BRENDA L. EHLMAN
94 ASHFORD DRIVE
ENOLA, PA 17025-2331
and
SOVEREIGN BANK
Garnishee,
and
M&TBANK
TO: M & T BANK
1 WEST HIGH STREET
CARLISLE, PA 17013
Defendant,
Garnishee.
CIVIL DIVISION
No. 07-4329 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 Jud ent against you.
R~sw~
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: ~~ ~ T BANK
n~ SAS NO OPEN ACCOUIV~
F(1R APOVE NPMF_f`
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.
e `
7
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:
~~Q
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:
,~14
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 ar~y interest.
RESPONSE:
N~4
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:
N~~
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.
r '
r
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:
N ~~
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:
~ I~
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).
RESPOiiNSE:
Nib
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
r
..
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: _/ ~~~
OATHY S. V=ISHER
1 9 ~'~ M&T BANK
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: l~
CATHY ANN CHRO AK, 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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SHERIFF'S RETURN - GARNISHEE
CF.,SE NO: 2007-04329 P
r
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
EHLMAN BRENDA L
And now JASON MORAL
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:44 Hours, on the 5th day of October 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
EHLMAN BRENDA L
in the
hands, possession, or control of the within named Garnishee
SOVEREIGN BANK 17 W HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JULIE MYERS (MANAGER)
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 ~,i
Service . 0 0 ~'~~~~'~ ~~i~~ ~
Affidavit .00 R. Thomas Kli e
Surcharge .00 Sheriff of Cumberland County
.00
. 0 0 / /oI/4~o 7
10/09/2007
Sworn and Subscribed to
before me this day of By
D pu y Sheriff
A.D
SHERIFF'S RETURN - GARNISHEE
C.7,~S~E• N0: 2007-04329 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
EHLMAN BRENDA L
And now JASON VIORAL
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:46 Hours, on the 5th day of October 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
EHLMAN BRENDA L in the
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
JESSICA REESE (SALES ASSOC) ,
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: S
Docketing . 0 0 '~ "~'~MC ~,~ ~-~
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
. 0 0 / /o~i y J~ ~
10/09/2007
Sworn and Subscribed to
before me this day of By
Dep y heriff
A.D
~.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
BRENDA L. EHLMAN,
and
SOVEREIGN BANK,
and
Defendant,
Garnishee,
CIVIL DIVISION:
No. 07-4329 CIVIL TERM
TYPE OF PLEADING:
Praecipe to Discontinue
Against Garnishees ONLY
TYPE OF CASE:
Civil Action
M&T BANK,
Garnishee. FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070 COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
Defendant's Address: PA ID N0.42067
94 ASHFORD DRIVE MAUREEN A. DOWD, ESQ.
ENOLA, PA 17025-2331 PA ID N0.90549
BETH ARNOLD HOWELL, ESQ.
PA ID NO.203606
CHRISTINE A. SAUNDERS, ESQ.
PA ID N0.203373
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
BRENDA L. EHLMAN,
and
SOVEREIGN BANK,
and
M&T BANK,
Defendant,
Garnishee,
Garnishee.
CIVIL DIVISION:
No. 07-4329 CIVIL TERM
PRAECIPE TO DISCONTINUE AGAINST GARNISHEES ONLY
TO THE PROTHONOTARY:
Please discontinue this action against the above garnishees, SOVEREIGN BANK and
M&T BANK, and mark the docket accordingly.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
BY~~_~ G~fla~~
CATHY ANN CHROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4~' Floor
Canonsburg, PA 15317
Sworn t and subscribed
Befor this day
of ~ , 2007.
~~
Notary blic
COMMONWEALTH OF PENNSYLVANIA
-~b~irfal Seed
Md'~eNe L. YYolota, No{8ry PubNC
r-ed~'n~.,'^'ee~pbn County
M~, ~.amr~~i~or- t~ireeJuly 7.2008
Member, r~BtltkSyfi~M; ;~ ".SOCtitlOn Ot NOteAss
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 Garnishees
Only was served upon the following by First Class Mail, postage prepaid on this 25TH day of
OCTOBER, 2007.
SOVEREIGN BANK
TIMOTHY J. GOONEY
P.O. BOX 841005
BOSTON, MA 02284
M&T BANK
CATHY FISHER
P. O. BOX #844
BUFFALO, NY 14240
BRENDA L. EHLMAN
94 ASHFORD DRIVE
ENOLA, PA 17025-2331
Cathy Ann Chromulak, Esq.
Maureen A. Dowd, Esq.
Beth Arnold Howell, Esq.
Christine A. Saunders, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff,
vs.
BRENDA L. EHLMAN
and
PNC BANK
and
WACHOVIA BANK
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
94 ASHFORD DR
ENOLA, PA 17025-2331
Date: Apri124, 2008
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Defendant,
Garnishee,
CIVIL DIVISION
No. 07-4329 CIVIL TERM
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
Garnishee. pA ID N0.42067
BETH ARNOLD HOWELL, ESQ.
PA ID N0.203606
TERESA K. FUCHS, ESQ.
PA ID N0.205696
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
DLSCOUNT COMPANY
Plaintiff,
vs.
BRENDA L. EHLMAN
and
PNC BANK
and
WACHOVIA BANK
Defendant,
Garnishee,
Garnishee.
CIVIL DIVISION
NO.07-4329 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
TO: The Prothonotary
Please issue a Writ of Execution in the above matter,
1. directed to the Sheriff of CUMBERLAND County;
2. against BRENDA L. EHLMAN, defendant, and, q~ A~sh~ord Dr, i/noia, Pa 170a5~d331
3. against PNC BANK, garnishee, and , 105 Noble af.VD , Cu.rltak, A4 !?a3
4. against WACHOVIA BANK, garnishee , (goy ~ Fhg1+ St, Carl~ate, vA nc~
5. and index this writ
a. against BRENDA L. EHLMAN, defendant, and
b. against PNC BANK, garnishee, and any property of the defendant in the name of
Garnishee, and
c. against wACHOVIA 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, bersonal and business.
6. 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.
$10,214.31
$382.50
$10,596.81
~.~ ~, j=u.~ti-a.
CATHY ANN CHROMULAK, ESQ.
BETH ARNOLD HOWELL, ESQ.
TERESA K. FUCHS, ESQ.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4329 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 BRENDA L. EHLMAN, 94 Ashford Drive, Enola, PA 17025-2331
(1) You are directed to lery 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, lOS Noble Blvd., Carlisle, PA 17013
WACHOVIA BANK, 604 E. High Street, Carlisle, PA 17013
any property of the defendant in the name of Garnishees
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 duected to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $10,214.31
Interest - $382.50
Atty's Comm
Atty Paid $191.40
Plaintiff Paid
Date: 4/28/08
L.L.
Due Prothy $2.00
Other Costs
Curti .Long, Pro
(Seal)
REQUESTING PARTY:
Name TERESA K. FUCHS, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L.C.
37S SOUTHPOINTE BOULEVARD, 4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
By:
Deputy
Telephone: 724-916-2400
Supreme Court ID No. 205696
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff s Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage
TOTAL
Advance Costs: 150.00
Sheriffs Costs: 140.87
18.00 9.13
2.77
.50
2.00 Refunded to Atty on 06/04/08
9.60
50.00
40.00
18.00 ~..
$ 140.87 / ~ ~~°~°P So Answers;
R. Thomas Kline, i~ri~
e
~Q~~ 11ll
C a~A. Br wbaker
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~~°~ ~ ~ a vs'.s
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4329 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 BRENDA L. EHLMAN, 2700 SANDERS RD., PROSPECT HEIGHTS, IL 60070
(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 SOVEREIGN BANK, GARNISHEE, 17 W. HIGH ST., CARLISLE, PA 17013 AND M & T
BANK, GARNISHEE, 1 W. HIGH ST., CARLISLE, PA 17013 -- PURSUANT TO ALL MONIES
DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND
BUSINESS.
GARNISHEE(S) as follows:
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 duected to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $10, 214.31
Interest $25.50
Atty's Comm
Atty Paid $162.40
Plaintiff Paid
Date: OCTOBER 2, 2007
(Seal)
REQUESTING PARTY:
L.L. $.50
Due Prothy $2.00
Other Costs
1J °pu[y
Name CHRISTINE A. SAUNDERS, ESQ.
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD
4Tn FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203373
`*
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-04329 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
EHLMAN BRENDA L
And now WILLIAM CLINE
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:55 Hours, on the 16th day of June 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
EHLMAN BRENDA L
hands, possession, or control of the within named Garnishee
PNC BANK 105 NOBLE BLVD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
in the
KIMBERLEE BOROSKY (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 answers:
Docketing . 00 ~ ,;,., ~+~~~
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
. 0 0 l~~19/6 ff ~-
06/17/2008
Sworn and Subscribed to
before me this day of By .~
Deputy Sheriff
A.D
,.. "•
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-04329 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
EHLMAN BRENDA L
And now WILLIAM CLINE
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0015:05 Hours, on the 16th day of June 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
EHLMAN BRENDA L
hands, possession, or control of the within named Garnishee
WACHOVIA BANK 604 EAST HIGH ST
in the
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
DANIELE HENRY (TELLER)
personally three copies of interogatories together with 3
and attested copies of the within COMPLAINT & NOTICE
the contents there of known to Her
true
and made
Sheriff's Costs: So ~~~~
Docketing .00
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
. oo ~ f,7Jo~
06/17/2008
Sworn and Subscribed to
before me this day of By
puty Sheriff
A.D
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
vs.
BRENDA L. EHLMAN
and
NO. 07-4329
WACHOVIA BANK, N.A.,
GARNISHEE :ATTORNEY I.D.#
ORDER TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly mark the attachment against the Garnishee, Wachovia Bank, National Association,
discontinued, upon payment of your costs only.
TERESA K. FUCHS
Attorney for Plaintiff
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R. Thomas Kline, Sheriff, who. being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken iri six months.
Sheriff s Costs:
Docketing 18.00
Poundage 2.76
Advertising
Law Library
Prothonotary 2.00
Milage 10.00
Misc.
Surcharge 50.00
Levy 40.00
Post Pone Sale
Certified Mail
Postage
Garnishee 18.00 n
140
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Advance Costs: 250.00
140.76
109.24
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4329 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 BRENDA L. EHLMAN, 94 Ashford Drive, Enola, PA 17025-2331
(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
WACHOVL4 BANK, 604 E. High Street, Carlisle, PA 17013
any property of the defendant in the name of Garnishees
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 $10,214.31
Interest - $382.50
Atty's Comm
Atty Paid $191.40
Plaintiff Paid
Date: 4/28/08
(Seal)
REQUESTING PARTY:
Name TERESA K. FUCHS, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD, 4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
L.L.
Due Prothy $2.00
Other Costs
Curtis .Long, Pr
By:
Deputy
Supreme Court ID No. 205696
R
vs.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
BRENDA L. EHLMAN,
and
Plaintiff,
Defendant,
Garnishee.
CIVIL DIVISION
No. 07-4329 CIVIL TERM
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
COMMERCE BANK,
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
94 ASHFORD DR.
ENOLA, PA 17025
Garnishee's Address:
65 ASHLAND AVE.
CARLISLE, PA 17013
Date: DECEMBER 3, 2008
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CATHY ANN CHROMULAK, ESQ.
PA ID N0.42067
/BETH ARNOLD HOWELL, ESQ.
PA ID NO.203606
TERESA K. FUCHS, ESQ.
PA ID N0.205696
JENNIFER M. PALONIS, ESQ.
PA ID NO.205703
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4`h Floor
Canonsburg, PA 15317
(724) 916-2400
~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
BRENDA L. EHLMAN,
Defendant,
and
COMMERCE BANK,
Garnishee.
CIVIL DIVISION
No. 07-4329 CIVIL TERM
PRAECIP~E FOR WRIT OF EXECUTION ~~~~.
0~1
TO: The Prothonotary
Please issue a Writ of Execution in t
1. directed to the Sheriff of
2. against BRENDA L. EH:
3. against COMMERCE Br
4. and index this writ
a. against BRENDA L.
b. against COMMERCI
name of Garnishee:
joint, personal and business.
5. Amount of Judgment
Additional Interest to
(Costs to be added)
Less
Pursuant to Writ of E
And Service of Writ
above matter,:
:JMBERLAND Cczunty; p 1702~5~
:AN, defendant, and R4 Ashfo~i Or, ~,no(a P
K, garnishee, (,05 ge[~,Su nd Ave , ~t-lis~t°, ~ I7b~3
.HLMAN, defendant, and
BANK, garnishee, and any property of the defendant in the
m
$10,214.31 - '~4 34.23
$ 320.02
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
$ 820.08
$ 9,714.25
CATHY ANN CHROMULAK, ESQ.
BETH ARNOLD HOWELL, ESQ.
TERESA K. FUCHS, ESQ.
JENNIFER M. PALONIS, ESQ.
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4329 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 BRENDA L. EHLMAN, 94 ASHFORD DRIVE, ENOLA, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the' property of the defendant(s) not levied upon in the possession
of COMMERCE BANK, ASHLAND AVE, CARLISLE, PA 17013 -ALL MONIES DUE
DEFENDANT IN ANY ACCOUNTS, INVIDIVUDAL AND JOINT, PERSONAL AND BUSINESS.
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) a~ 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~P you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $9,394.23
Interest TO DATE - $320.02
Atty's Comm
Atty Paid $530.53'
Plaintiff Paid
Date: DECEMBER 5, 2008
(Seal)
REQUESTING PARTY:
Name BETH ARNOLD HOWELL,
Address: CHROMULAK &
375 50UTHPOINTE
4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 203606
L.L. $.50
Due Prothy $2.00
Other Costs
Curt' R. Long, o o ary
By:
', Deputy
L.L.C.
IN THE COURT OF COMMON PLEAS OF
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
BRENDA L. EHLMAN,
XXX-XX-4340
94 ASHFORD DR.
ENOLA, PA 17025
and
COMMERCE BANK
Defendant,
Garnishee.
TO: COMMERCE BANK
65 ASHLAND AVE.
CARLISLE, PA 17013
COUNTY, PENNSYLVANIA
No. 07-4!329 CIVIL TERM
You are required to file Answers to the following interrog~
service upon you. Failure to do so may re ult //i'n /IJudgment
~vV~~
within twenty (20) days after
.t you.
FIRST; At the time you were served or at any subseq ent time did you owe the Defendant
any money or were you liable to him/her on any negotiable o other written instrument, or did
he/she claim that you owed him/her any money or that you re liable to him/her for any reason:
Defendant had account 53651655 held inriivid~ 1_y with a balance of $~'~.74. Account
RESPONSE: is direct deposit (payroll). Defendant did n t receive X300 er~'~ion.
SECOND: If your response to the previous interrogatory
unqualified negative, set forth the amount of the claim, and i
any, that forms the basis of the claim.
RESPONSE: ~ az~`~rer to q~'estion 1
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
anything other than an
fY the written instrument, if
THIRD: At the time you were served or at any subsequ
possession, custody or control or in the joint possession, cust
or more persons any property of any nature owned solely or i~
of this interrogatory encompasses, but is not restricted to, the
RESPONSE: ~ ans<aer toi question 1
FOURTH: If your response to the previous interrogatory
unqualified negative, identify the property, and in the case of
RESPONSE: No
FIFTH: At the time you were served or at any sub
any property of any nature owned solely or in part by the
held or claimed any interest.
RESPONSE: No
SIXTH: If your response to the previous interrogatory
unqualified negative, identify the property, and in the case of
RESPONSE: No
SEVENTH: At the time you were served or at any s
any property in which the Defendant had any interest?
RESPONSE: No
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
It time, was there in your
iy or control of yourself and one
part by the Defendant? The scope
of any bank account(s).
anything other than an
ietary assets, state the amount.
time, did you hold legal title to
ant (or in which Defendant)
anything other than an
ietary assets, state the amount.
time, did you hold as a fiduciary
4
EIGHTH: If your response to the previous interrogatory
unqualified negative, identify the property, and in the case of
RESPONSE: NO
any property to you or to any person or place pursuant to
what was the consideration therefore?
NINTH: At any time before or after you were served,
RESPONSE: No
TENTH: If your response to the previous interrogatory
unqualified negative, identify the property, and in the case of
and state the date of the transfer and the name and address of
RESPONSE: No
ELEVENTH: At any time after you were served, did you pa
property of the Defendant or to any person or place pursuant
discharge any claim of the Defendant against you?
RESPONSE: No
TWELFTH: If your response to the previous interrogat
unqualified negative, identify the property, in the case of
state the date of transfer and the name and address of the
RESPONSE: No
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
anything other than an
assets, state the amount.
d the Defendant transfer or deliver
direction or consent and, if so,
was anything other than an
monetary assets, state the amount,
the transferee(s).
~, transfer or deliver any money or
:o their direction or otherwise
anything other than an
y assets, state the amount, and
ye(s).
THIRTEENTH: If you are a bank or other financial instituti~
at any,subsequent time did the defendant have funds on depo:
deposited electronically on a recurring basis and which are ids
deposit are exempt from execution, levy or attachment under
identify each account and state the reason for the exemption z
depositing those funds on a recurring basis
RESPONSE: See ar~x to que~ction 1
FOURTEENTH: If you are a bank or other financial institu
at any subsequent time did the defendant have funds on depo;
on deposit, not including any otherwise exempt funds, did no
monetary exemption under 42 PaC.S. Section 8123? If so, id
RESPONSE: ~ ~ to question 1
n, at the time you were served or
it in an account in which funds are
ntified as being funds that upon
?ennsylvania or federal law? If so;
:~d the entity electronically
ion, at the time you were served or
it in an account in which the funds
exceed the amount of the general
:ntifv each account
Respectfully su miffed,
CHROMULA & ASSOCIATES, L.L.C.
C~~ By:
DATE: 11r1~`_PXY~t ~
~
Cathy Ann Chr mulak, Esq.
Beth Arnold H ell, Esq.
Teresa K. Fuch ,Esq.
Jennifer M. Pal nis, Esq.
375 Southpoint Boulevard
4`h Floor
Canonsburg, P 15317
(724) 916-2400
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
VERIFICATION
The undersigned does hereby verify subject to the penal
to unsworn falsifications to authorities, that he/she is
Levy Specialist of Commerce Bank/Harr
(Title) (Company)
that he/she duly authorized to make this verification, and that the
Answers to Interrogatories are true and correct to the best of hi
belief.
of 18 PA. C.S. § 4904 relating
(Name)
garnishee herein,
set forth in the foregoing
knowledge, information and
(SIC~QATURE)
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-04329 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
EHLMAN BRENDA L
And now TIMOTHY R. BLACK
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:55 Hours, on the 10th day of December 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
EHLMAN BRENDA L
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE
in the
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
MARIA T. THEODORATOS (CSR
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her .
true
and made
Sheriff's Costs: So~ .~
Docketing .00
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00 /~j_ ~~~I~~OF~
. 0 0 ~'"`
12/11/2008
Sworn and Subscribed to
before me this day of By
eputy Sheriff
A.D
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
BRENDA L. EHLMAN,
CIVIL DIVISION
No. 07-4329 CIVIL TERM
TYPE OF PLEADING:
Praecipe to Discontinue
Against Garnishee ONLY
Defendant,
AND
COMMERCE BANK,
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
A ID N0.42067
ETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
TERESA K. FUCHS, ESQ.
PA ID N0.205606
JENNIFER M. PALONIS, ESQ.
PA ID N0.205703
CHROMtTLAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4~' 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.
BRENDA L. EHLMAN,
and
COMMERCE BANK,
Defendant,
Garnishee.
CIVIL DIVISION
No. 07-4329 CIVIL TERM
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
Please discontinue this action against the above garnishee, COMMERCE BANK and
mark the docket accordingly.
Sworn to and subscr eIi
Befo me this _day
of ~ , 2008.
No - -- voterial Sbal
M~Ct+eiit ; Wolota. Notary Publlc
~'~ ~ ~ ' wN. `Naahington County
~y ~. mission Expires JuIY 7.201
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By:1 ~P~. ~~_x~
CATHY ANN CHROMULAK, ESQUIRE
BETH ARNOLD HOWELL, ESQUIRE
TERESA K. FUCHS, ESQUIRE
JENNIFER M. PALONIS, ESQUIRE
Attorneys for Plaintiff
375 Southpointe Boulevard
4~' 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, 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 29th day of
December, 2008.
COMMERCE BANK
JENNIFER HILBISH
LEVY DEPARTMENT
3801 PAXTON ST.
HARRISBURG, PA 17111
BRENDA L. EHLMAN
718 MEADOW DRIVE
CAMP HILL, PA 17011
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.
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff s Costs:
Docketing
Poundage
Law Library
Prothonotary
Mileage
Surcharge
Levy
Postage
Garnishee
18.00
1.70
.50
2.00
4.50
30.00
20.00
.88
9.00
$ 86.58 +~ 4~- f/o y
Advance Costs: 150.00
Sheriff's Costs: 86.58
63.42
Refunded on 06/16/09
So Answers, ~~
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R. ho~m~as Kline, She iff
/ Sharon R. Lantz
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4329 Civil
CIVII. ACTION - t.A~
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOLiN'f
COMPANY, Plaintiff (s)
From BRENDA L. EHLMAN, 94 ASHFORD DRIVE, ENOLA, PA 1.7025
(1) You are directedto 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 possessio^
of COMMERCE BANK, ASHLAND AVE, CARLISLE, PA 17013 -ALL MONIES DUE
DEFENDANT IN ANY ACCOUNTS, INVIDIVUDAL AND JOINT, PERSONAL ANll BUSINESS.
GARNISHEE(S) as follows:
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 iu the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added a5 a
garnishee and is enjoined as above stated.
Amount Due $9,394.23
Interest TO DATE - $320.02
L.L. $.50
Atty's Comm
Atty Paid $530.53'
Plaintiff Paid
Date: DECEMBER 5, 2008
(Seal)
REQUESTING PARTY:
Name BETH ARNOLD HOWELL, ESQUIRE
Due Prothy $2.00
Other Costs
__ _ __
Cu is R. Long
By:
Deputy
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD
4TH FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2 400
Supreme Court ID No. 203606