HomeMy WebLinkAbout03-5544IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
VS.
DONALD A. SHEETZ
and
SHIRLEY M.SHEETZ
Defendants.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
132 East Liberty Avenue
Carlisle, PA 17013
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
DATE: ?{D?02 C l8 Z o03
CIVIL DIVISION
No. 03 - Shy `f ?? l 2,6 -
TYPE OF PLEADING:
Complaint
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
SCOTT E. CRAWFORD, ESQ.
PA ID NO. 89570
MOLLICA & CHROMULAK
Firm #952
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211-1205
(412) 381-7000
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
Plaintiff, CIVIL DIVISION
Vs.
No.
DONALD A. SHEETZ and SHIRLEY M. SHEETZ
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 HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166 OR 800-990-9108
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CIVIL DIVISION
MORTGAGE COMPANY OF S?? c
3
PENNSYLVANIA, No. 0
Plaintiff,
VS.
DONALD A. SHEETZ
and
SHIRLEY M.SHEETZ,
Defendants.
COMPLAINT
AND NOW COMES, the Plaintiff, BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, by its
Attorneys, Mollica & Chromulak, with its Civil Action Complaint, the following of which is a
statement thereof:
1. BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF PENNSYLVANIA 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. DONALD A. SHEETZ and SHIRLEY M. SHEETZ are adult individuals residing
at 132 East Liberty Avenue, Carlisle, PA 17013.
3. On or about October 6, 1999, Defendants entered into a Loan Agreement with the
Plaintiff, a copy of which is attached hereto as "Exhibit A" and incorporated herein.
4. Pursuant to the 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 December 6, 2002.
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, and owing by the
Defendants is in the sum of Six Thousand, Nine Hundred Sixty-Five and 06/100 ($6,965.06)
Dollars as of September 9, 2003.
Numerous demands have been made upon the Defendants by Plaintiff, but the
Defendants have failed or refused to pay.
8. Pursuant to the Loan Agreement, Plaintiff is entitled to recover costs of collection
and reasonable attorney's fees.
WHEREFORE, Plaintiff claims damages in the sum of Six Thousand, Nine Hundred
Sixty-Five and 06/100 ($6,965.06) Dollars, plus court costs and attorney's fees.
Respectfully submitted,
Mollica & Chromulak
By: C4:?&4E •ctOVIQ
DATE: a-a bu 16,Za03 CATHY ANN C OMULAK, ESQ.
PA ID NO. 42067
SCOTT E. CRAWFORD, ESQ.
PA ID NO. 89570
Attorneys for Plaintiff
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
, LOAN REPAYMENT AND SECURITY AGREEMENT (Page I of 3)
LENDER (called "We", "Us", "Our")
BENEFICIAL CONSUMER DISCOUNT COMPANY DiSIA BENEFICIAL MORTGAGE CO OF PENNSYLVANIA
4910 CARLISLE PIKE1#104
MECHANICSBURG PA 11055
BORROWERS (called "You", "Your")
SHEETZ. DONALD A
SS# '189448043
SHEETZ. SHIRLEY M
SS# 159448880
132 E LIBERTY AVE
CARLISLE PA 11013
s 289.38
RELI INS PREMIUM
t NONE
LOAN NO: 111114-511551
yn?'
?fi pc3nEg?pNT I g?7?7E?7STECONDAgRYy gMORTGAGE LOAN
YOU ARzHt ffif G pJ SEt6W 7?-rNplERp TPN?If?FRIEA?FEtST1?TE LOGA7 tuYA?P -TFit A?OVE?AL1?Rl=5S.
'6'..:o- .r,. n: in•.. ;. _..,
r
REQUIRED INSURANCE. You must obtain insurance for term of loan covering security for tbn Ices as indicated by,thi'
word "YES' below. naming us as Loss Pa?aw: - '
Zitle insurance on real estate security.
Fire and extended coverage insurance on reel stele security- - yJ. .
Physical damage insurance on vehicle listed under "Security" above.tf Y appasra under"Insurad?;d , 4? >, : e,
Physical damage it'suraace on other property listed under 'Security" ,above if :'Y" nppedra;nnderl"Iiutirad a
' n ot'iaeursaoe
_ You may obtain any required insurance from snpone you choose had may assign say other polr p .
"ri'•i` you own to cover the security for this lost'. ; .. - .. ..
ISea •Security" paragraph above for description of security to be insured.)
pp NOTICE: THE FOLLOWING PAGES CONTAIN ADDITIONAL CONTRACT TERMSc P?559t1
.. 2NO NRG RE SI .
ORIGINAL .3q ?,j ????al I®®?UIII1191?? -.t ti,
" LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3)
PAYMENT:' In` retgr"n for your loan described below, you agree to pay us, the Principal and Interest computed at the'` 1
"Contiict'Ratct(`as. on page one), Principal is Amount Financed, plus The Fee. You shall pay us monthly
ppyments 'at our busineas-wWress or other address given you. If more than one Borrower is named on page one, we
'. ,inay;enforce thiS_Contract against all, or any Borrowers, but not in a combined amount greater than the amount owed.
? Each,paynent will"be first applied to any Late Charges, then to Interest at the Contract Rate for the actual time.
outstanding, and the remainder to your unpaid Principal.
DATE;ON WHICH INTEREST BEGINS. If you do not cancel this loan, the date on which Interest begins, payment.`:-
dates, and effective-date of insurance purchased are postponed by the number of days from this contract's date to date
you ieceiSe this loan.,
,PAY-OUTS.You•agree to payouts of Amount Financed as shown on Truth-In-Lending disclosure form. If payouts
ch6oge-be6ause to'sn'closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check
'.w'illt,15 reduced to "cover additional payouts.
PREPAYMENT: You may prepay your loan. at any time. Prepayment will reduce the Interest, because it is computed
by:: the,simple interest method. The Principal is fully earned when this loan is made.
LATE CHARGE. We will charge you a late charge if you don't pay any payment in full in 15 days after it's due date'.
The Late Charge is equal to 10% of the Monthly Installment or $20.00, whichever is greater.
BAD CHECK CHARGE.. We will charge you a fee of S20 if any payment check is returned because of insufficient
1=14. or is otherwise dishonored. You agree that we may deduct this charge from a monthly payment.
SECURITY. If disclosed on page one, you also agree to give us a security interest in the property identified on page
one. You agree to give us a security interest in the real estate as described in the MortgagelDeed of Trust.
PROPERTY INSURANCE:
A..YOUR OBLIGATION TO INSURE. You shall keep the structures located on the real property securing this loan
insured against damage caused by fire and other physical hazards, name us as a loss payee and deliver to us a loss
payable endorsement. If insurance covering the real property is cancelled or expires while the loan is outstanding and
qou do not reinstate the coverage, we may obtain, at our option, hazard insurance coverage protecting our interest in,,
the real property as outlined below.
B. LENDER'S RIGHT TO PLACE HAZARD INSURANCE. You authorize us, at our option, to obtain coverage on
the Property in an amount not greater than the outstanding balance of principal and interest on the loan or, if known
to be less, the replacement value of the Property, in the event that you fail to maintain the required hazard insurance
outlined above or fail to provide adequate proof of its existence. You authorize us to charge you for the costs of this
`insuraax- and add the insurance charges to your loan. The Insurance charges will be added to the unpaid balance of the
loan which accrues interest at the Contract Rate. The addition of the insurance charges due might increase the amount
of your final installment. The cost of Lender placed hazard insurance might be higher than the cost of standard _
insurance protecting the property. The Lender placed insurance will not insure the contents of the property or provide
liability coverage. The insurance might not be the lowest cost coverage of its type available and you agree that we have
no obligation to obtain the lowest cost coverage. We or an affiliated company might receive some benefit (i.e.
commission, service fee, expense reimbursement, etc.) from the placement of this insurance and you will be charged
for the full cost of the premium without reduction for any such benefit. If at any time after we have obtained this
insurance, you provide adequate proof that you have subsequently purchased the required coverage, we will cancel the
coverage we obtained and credit any unearned premiums to your loan.
NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS.
7-01-99 RE $,
.W6...
. .. ORIGINAL
PASS6912 ' .:;c
?Pr?l .c -.t '.. .. .Ie ,...r. ::?t`. c ra. ? .ts.:r•..,: s„
LOAN REPAYMENT AND SECURITY AGREEMENT (Page 3 of 3)
DEFAULT, If you don't pay on time or fail to keep any required insurance in force, or if permitted in the event of default
under the Mortgage, (1) all your payments may become due at once and, (2) without notifying you before bringing suit, we
may sue you for the entire unpaid balance of Principal and accrued Interest and (3) any judgment in our favor may include
our reasonable attorney's fee and court costs as determined by the court. You agree that, should we obtain judgment
against you, a portion of your disposable earnings may be attached or garnished (paid to us by your employer), as provided
by Federal law. You agree to pay interest on any judgment at the Contract Rate.
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 8602, Elmhurst, IL 60126.
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.
OPTIONAL INSURANCE. Optional Credit Insurances and any required insurance disclosures are attached to this
Agreement and are incorporated herein by reference.
APPLICABLE LAW. This loan is made under the Pennsylvania Secondary Mortgage Loan Act, Title 7, Purdon's
Pennsylvania Statutes. This loan also may qualify as an "alternative mortgage transaction" under the Alternative Mortgage
Transactions Parity Act Section of the Garn-St. Germain Depository Institutions Act of 1982, Sections 3801 td 3806, Title
12, United States Code.
If you do not pay the full amount of an instalment when it is due, and we intend to foreclose on the Mortgage, we must
comply with the provisions of Section 403 and 404 of the Act of January 30, 1974, which is known as Act No. 6, and the
provisions of the Homeowner's Emergency Mortgage Assistance Act (Act No. 91 of 1983). •
ANY ADVANCE OF FUNDS PURSUANT TO THIS CREDIT LINE ACCOUNT AGREEMENT AND THE
MORTGAGE WHICH SECURES THE AGREEMENT MAY, IN THE EVENT OF ANY DEFAULT, RESULT
IN THE LOSS OF YOUR HOME OR OTHER REAL PROPERTY PLEDGED AS SECURITY FOR YOUR
LOAN,
YOU HAVE RECEIVED A COMPLETE
COPY OF THIS AGREEMENT AND THE
TRUTH-IN-LFNDING Drcrl.nSiTRFS
L)
B ow7Y- *(SEAL)
WITNESS: (SEAL)
NV NI G9 RE SI - PAB55973 .
ORIGINAL MINIMUM
Z0'39dd 06S8TG5£T8
SEP 23 2003 10:13 FR MOLLICA AND MUWY
4123BMII M 8510400000009181 P.02/02
05:60 CO, £Z d3S
VEMICATION
I, Angela Davis, Sr. Clerk for
BENEFICIAL CONSUMER DISCOUNT COM?ANY; A HOUSHEOLD INTERNATIONAL COMpAN`I
Angela Davis
Dated: 10-16-2003
** TnTAA POM.90 **
verily that the facts set forth in the fbregoing Complaint are true and correct to the best of
my knowledge, information and belief, and that I am authorized to verify suoh Complaint
on behalf of BENEFICIAL
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
4904 relating to unworn falsification to authorities.
7n'J Tr•77 nnn7 n7 A2a
nCrOTJr TO•YCJ
nJu
W
C da
W
d
i
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-05544 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT C
VS
SHEETZ DONALD A ET AL
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SHEETZ DONALD A
the
DEFENDANT , at 1404:00 HOURS, on the 23rd day of October 2003
at 132 EAST LIBERTY AVENUE
CARLISLE, PA 17013
by handing to
SHIRLEY M SHEETZ, WIFE
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 3.45
Affidavit .00
Surcharge 10.00
.00
31.45
Sworn and Subscribed to before
me this 4 day of
`wxm.-Ctc,? „?.,Gt7-3 A.D.
rothonotary
So Answers:
.e
R. Thomas Kline
10/24/2003
MOLLICA & MURRAY
By:
Deputy Shed!' ff
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-05544 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT C
VS
SHEETZ DONALD A ET AL
HAROLD WEARY
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SHEETZ SHIRLEY M the
DEFENDANT , at 1404:00 HOURS, on the 23rd day of October , 2003
at 132 EAST LIBERTY AVENUE
CARLISLE, PA 17013
SHIRLEY M SHEETZ
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
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00 R. Thomas Kline
.00
16.00 10/24/2003
MOLLICA & MURRAY
Sworn and Subscribed to before By:
me thisn (. V day of
7 6-ut v„?.Q.u o2U?-3 A.D.
9roth on otapy
ry
7puty Sher
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
vs.
DONALD A. SHEETZ AND
SHIRLEY M. SHEETZ,
Defendants.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendants' Address:
132 EAST LIBERTY AVENUE
CARLISLE PA 17013
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CIVIL DIVISION
No. 03-5544 CIVIL TERM
TYPE OF PLEADING:
Praecipe For Entry
Of Consent To Judgment
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
SCOTT E. CRAWFORD, ESQ.
PA ID NO. 89570
MOLLICA & CHROMULAK
Firm #952
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211-1205
(412) 381-7000
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
vs.
DONALD A. SHEETZ AND
SHIRLEY M. SHEETZ,
Defendants.
CIVIL DIVISION
No. 03-5544 CIVIL TERM
PRAECIPE FOR ENTRY OF CONSENT TO JUDGMENT
TO PROTHONOTARY:
Please enter judgment in favor of Plaintiff, BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA and against
Defendants, DONALD A. SHEETZ AND SHIRLEY M. SHEETZ, in the amount of SEVEN
THOUSAND THREE HUNDRED FIFTY-SEVEN AND 061100 ($7,357.06), with interest
thereon at the legal rate of 6% from NOVEMBER 3, 2003, as evidenced by the Consent to
Judgment attached hereto as Exhibit A.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Respectfully submitted,
MOLLICA & CHROMULAK
By: S0g#rG&"`4*""
Scott E. Crawford, Esq.
-?;
?`
,;
?..
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CIVIL DIVISION
MORTGAGE COMPANY OF No. 03-5544 CIVIL TERM
PENNSYLVANIA,
Vs.
Plaintiff,
DONALD A. SHEETZ AND
SHIRLEY M.SHEETZ
Defendants.
CONSENT TO JUDGMENT
AND NOW, to wit, this I I'-'!h day of NOVerv&ber , 2003, with the
consent of all parties and their respective counsel, it is agreed as follows:
Judgment shall be and is hereby entered against Defendants DONALD A. SHEETZ AND
SHIRLEY M. SHEETZ in the amount of SEVEN THOUSAND THREE HUNDRED
FIFTY-SEVEN AND 06/100 ($7,357.06) DOLLARS plus interest on the unpaid balance
at the rate of 6% per annum commencing on NOVEMBER 3, 2003.
2. Defendants DONALD A. SHEETZ AND SHIRLEY M. SHEETZ agree to make
payments to Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a
BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA in the amount of ONE
HUNDRED EIGHTY-THREE AND 00/100 ($183.00) DOLLARS on or before the
25TH day of each month for FORTY-FIVE (45) consecutive months, until the entire debt
owing Plaintiff is paid in full. The first payment shall be due on or before NOVEMBER
25, 2003.
Payments shall be sent to Plaintiff BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA in
care of Mollica & Chromulak, 450 Trimont Plaza, 1305 Grandview Avenue, Pittsburgh,
PA 15211, or any other address Plaintiff BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA may
later designate.
EXHIBIT
I A
n C 1: 1
T
n f i i
r'
m rr ? -
. tr
4. Defendants DONALD A. SHEETZ AND SHIRLEY M. SHEETZ have induced
Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF PENNSYLVANIA, and Plaintiff BENEFICIAL
CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA agrees to forbear in the enforcement of its rights
against them so long as Defendants DONALD A. SHEETZ AND SHIRLEY M.
SHEETZ make timely payments. If Defendants DONALD A. SHEETZ AND
SHIRLEY M. SHEETZ fail to make timely payments, then Plaintiff BENEFICIAL
CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA may institute or take all steps necessary,
appropriate or helpful to collect the judgment, represented hereby, together with the
Plaintiff's costs of collection and attorneys fees therefore.
AND NOW, on the date written above, the parties set forth their hands and seals as follows:
a
ru 2 `f 2 s-r Q4-
fir tness vNALD A
'k
tnest
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
SHIRLEY M. EHEETZ
Scott E. Crawford, Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Scott E. Crawford, Esquire, counsel for Plaintiff, BENEFICIAL CONSUMER
DISCOUNT COMPANY d/b/a BENEFICIAL MORTGAGE COMPANY OF
PENNSYLVANIA, hereby certify that a true and correct copy of the foregoing
PRAECIPE FOR ENTRY OF CONSENT TO JUDGMENT was served upon the
acx-h
following by United States First Class Mail, postage prepaid on this day of
govembu , 2003:
DONALD A.SHEETZ
132 EAST LIBERTY AVENUE
CARLISLE PA 17013
SHIRLEY M.SHEETZ
132 EAST LIBERTY AVENUE
CARLISLE PA 17013
,e* fJ
Scott E. Crawford, Esq.
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
?,
ri
??
?'?' ? ?
-C
4
? ?
-?
?<
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT CIVIL DIVISION
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF No. 03-5544 CIVIL TERM
PENNSYLVANIA,
Plaintiff,
VS.
DONALD A. SHEETZ AND
SHIRLEY M. SHEETZ,
Defendants.
NOTICE OF ORDER DECREE OR JUDGMENT
TO: DONALD A. SHEETZ
132 EAST LIBERTY AVENUE
CARLISLE PA 17013
(X) Defendant
You are hereby notified th an Order, Decree or Judgment was entered in the above-
captioned proceeding on 7t e- S ? :x(-U 3
() A copy of the Order or Decree is enclosed, or
(X) The judgment is as follows: SEVEN THOUSAND THREE HUNDRED
FIFTY-SEVEN AND 06/100 ($7,357.06), plus interest at the legal rate of
6% per annum and additional costs of suit.
Dep / 7),
tL? ?
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
w? s
14,
?CLE
t
o?
c•
vc7,-
Z C:
U?
4
i
r.
'V
C
fo
*i
J?
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-05544 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT C
VS
SHEETZ DONALD A
And now MICHAEL ICKES , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according
to law, at 0013:55 Hours, on the 15th day of July , 2005, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
SHEETZ DONALD A in the
hands, possession, or control of the within named Garnishee
ORRSTOWN BANK 22 S HANOVER ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JACKIE JUMPER (HEAD TELLER CSR)
personally 3 true and attested copies of the within
WRIT OF EXECUTION and made the contents thereof known to Her .
Sheriff's Costs: So answers:
Docketing .00
Service .00
Affidavit 00?
Surcharge .00 R. Thomas Kline'
.00 Sheriff of Cumberland County
.00
07/18005
By Sworn and subscribed to before me
this day of
D.
Pr t onotary
Deputy Sheriff
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-05544 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT C
VS
SHEETZ DONALD A ET AL
And now MICHAEL ICKES , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according
to law, at 0013:55 Hours, on the 15th day of July , 2005, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
SHEETZ SHIRLEY M in the
hands, possession, or control of the within named Garnishee
ORRSTOWN BANK 22 S HANOVER ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JACKIE JUMPER (HEAD TELLER, CSR)
personally 3 true and attested copies of the within
T OF EXECUTION and made the contents thereof known to Her
Sheriff's Costs: So answers:
Docketing .00
Service .00rwq?„???
Affidavit .00
Surcharge .00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00
07/18/2005
BPD ?J?i
13Y
Deputy Sheriff
Sworn and subscribed to before me
this /y E-1 day of
2uvs' A.D.
-fir thonotary?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
CIVIL DIVISION
No. 03-5544 CIVIL TERM
Plaintiff,
vs.
DONALD A. SHEETZ and
SHIRLEY M.SHEETZ,
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
Defendants, BENEFICIAL CONSUMER DISCOUNT
and COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
ORRSTOWN BANK, PENNSYLVANIA
Garnishee.
COUNSEL OF RECORD:
Plaintiffs Address: CATHY ANN CHROMULAK, ESQ.
2700 Sanders Road PA ID NO. 42067
Prospect Heights, IL 60070 MELISSA A. SHENKEL, ESQ.
PA ID NO. 91445
Defendant's Address:
132 EAST LIBERTY AVENUE
CARLISLE, PA 17013
Garnishee's Address:
22 S. HANOVER STREET
CARLISLE, PA 17013
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
Date: JULY 6, 2005
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 d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
vs.
DONALD A. SHEETZ and
SHIRLEY M. SHEETZ,
Defendants,
and
ORRSTOWN BANK,
Garnishee.
CIVIL DIVISION
No. 03-5544 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 DONALD A. SHEETZ and SHIRLEY M. SHEETZ, defendants, and
3. against ORRSTOWN BANK, garnishee,
4. and index this writ
a. against DONALD A. SHEETZ and SHIRLEY M. SHEETZ, defendants, and
b. against ORRSTOWN BANK, garnishee, and any property of the defendants in
the name of Garnishee:
Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual
and ioint, personal and business.
5. Amount of Judgment
Additional Interest to Date
Less Payments Made
(Costs to be added)
$7,357.06 4dt[6.OL
$ 399.00
(3,111.00)
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.
$4,645.06
MELIS A. SHENKEL, ESQ.
a• n
V
V
4.A
h
-11
010 93 vt '-
Z
=4 c o c a
Q
-
VI
1
C p
1 Cz?
?v
T n
CN
3
^sa
< r
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5544 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY
DB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, Plaintiff (s)
From DONALD A. SHEETZ AND SHIRLEY M. SHEETZ, 132 EAST LIBERTY AVENUE,
CARLISLE, PA 17013
(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 ORRSTOWN BANK, 22 S. HANOVER STREET, CARLISLE, PA 17013 -
INTERROGATORIES
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 $4,246.06 L.L. $.50
Interest $399.00
Atty's Comm % Due Prothy $1.00
Airy Paid $82.00 Other Costs
Plaintiff Paid
Date: JULY 11, 2005
CURTIS R. LONG
PTmhonota
(Seal) By Q4>? C'-L? /LiY
C?
Deputy
REQUESTING PARTY:
Name MELISSA A. SHENKEL, ESQUIRE
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. 91445
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
VS.
DONALD A. SHEETZ
and
SHIRLEY M.SHEETZ,
Defendant,
and
CIVIL DIVISION
No. 03-5544 CIVIL TERM
TYPE OF PLEADING:
Praecipeto Discontinue
Against Garnishee ONLY
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
ORRSTOWN BANK, BENEFICIAL CONSUMER DISCOUNT
Garnishee. COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA
Plaintiff's Address:
2700 Sanders Road COUNSEL OF RECORD:
Prospect Heights, IL 60070
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MELISSA A. SHENKEL, ESQ.
PA ID NO. 91445
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4`h 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 d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
V5.
DONALD A. SHEETZ
and
SHIRLEY M. SHEETZ
and
ORRSTOWN BANK,
Defendant,
Garnishee.
CIVIL DIVISION
No. 03-5544 CIVIL TERM
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TOPROTHONOTARY:
Please discontinue this action against the above garnishee, ORRSTOWN BANK and
mark the docket accordingly.
Sworn to and subscribed
Before me this o?4/ day
of, 2005.
f
OF N S
;'no
Not ubli"0d Ile L WO ota, Notary Putdic
Cecil Twp., Washington County
My Commission E)Ores July 7, 2008
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By
CA HY ANN CHROMULAK, ESQUIRE
MELISSA A. SHENKEL. ESQUIRE
Attorneys for Plaintiff
375 Southpointe Boulevard
4`h 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, Melissa A. Shenkel, Esquire, counsel for BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, 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 26 day of
JULY, 2005.
ORRSTOWN BANK
22 SOUTH HANOVER STREET
CARLISLE, PA 17013
DONALD A.SHEETZ
and SHIRLEY M. SHEETZ
132 EAST LIBERTY AVENUE
CARLISLE, PA 17013
i
elissa. Shenkel, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
(?) ?';
? ??
i
_
n ?
i
( '
,
°? (^J
r L
Y.. _ G'i ?
_t?
?
-r _
V :::? hJ <
6?
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5544 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY
DB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, Plaintiff (s)
From DONALD A. SHEETZ AND SHIRLEY M. SHEETZ, 132 EAST LIBERTY AVENUE,
CARLISLE, PA 17013
(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 ORRSTOWN BANK, 22 S. HANOVER STREET, CARLISLE, PA 17013 -
INTERROGATORIES
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 $4,246.06 L.L. $.50
Interest $399.00
Atty's Comm % Due Prothy $1.00
Atty Paid $82.00 Other Costs
Plaintiff Paid
Date: JULY 11, 2005
CURTIS R. LONG
Prothonota
(Seal) By:
Deputy
REQUESTING PARTY:
Name MELISSA A. SHENKEL, ESQUIRE
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. 91445 TRUE COPY MOM RECORD
In Te311 W?vy 11 _ I -'re unto vet my hand
-nd -t Par"We' Pa.
# 3 Jx?'Av 1
t
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: Advance Costs: 150.00
Sheriffs Costs 84.15
Docketing 18.00 65.85
Poundage 1.65
Advertising
Law Library
Prothonotary .50
1.00
Refunded to Atty on 5/16/06
Mileage 4.00
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
l
=
Certified Mai
Postage
Garnishee 9.00 j
TOTAL 84.15 r /?• ..?
Swo d Subscribed to efore me
c3
So Answers;
this day R. Thomas Kline, Sheriff
B U
_ 2006 A.D. y
,t
yet?? •????? ??
D j%541
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
VS.
DONALD A. SHEETZ and
SHIRLEY M. SHEETZ,
and
ORRSTOWN BANK,
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendants
Garnishee.
CIVIL DIVISION
No. 03-5544 CIVIL TERM
TYPE OF PLEADING:
Praecipe to Discontinue
Against Garnishee ONLY
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA 11) NO. 42067
LORI M. DIRENZ09 ESQ.
PAID NO. 201843
AMY L. SABOLCHICK, ESQ.
PA ID NO. 94653
ANNA M. BONARRIGO, ESQ.
PA ID NO. 202070
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 CIVIL DIVISION
COMPANY dlb/a BENEFICIAL No. 03-5544 CIVIL TERM
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
VS.
DONALD A. SHEETZ and SHIRLEY M. SHEETZ,
Defendants
and
ORRSTOWN BANK,
Garnishee.
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
Please discontinue this action against the above garnishee, ORRSTOWN BANK and
mark the docket accordingly.
Respectfully submitted,
CHROMU A? & ASSOQATES, L.L.C
By: 1 f if k L !V 1 L 1
CATHY-KNN CHRO LAK, E UI'RE
LORI M. DIRENZO, ESQUIRE ',
AMY L. SABOLCHICK, ESQUIRE
ANNA M. BONARRIGO, ESQUIRE
Attorneys for Plaintiff
375 Southpointe Boulevard
4`h Floor
Canonsburg, PA 15317
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Sworn to and subscribed
Before a this Ind' day
of r , 2006.
K
CERTIFICATE OF SERVICE
I, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF PENNSYLVANIA, 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 10th day of August, 2006.
ORRSTOWN BANK
22 S. HANOVER STREET
CARLISLE, PA 17013
DONALD A. SHEETZ
SHIRLEY M. SHEETZ
132 EAST LIBERTY AVE.
CARLISLE, PA 17013
C thy Ann Chroif rak; Esq. /
Maureen A. Dowd, Esq.
Lori M. DiRenzo, Esq.
Amy L. Sabolchick, Esq.
Anna M. Bonarrigo, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
1 ?
Y G=
J
i
t
1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
VS.
DONALD A. SHEETZ and
SHIRLEY M. SHEETZ,
and
ORRSTOWN BANK,
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
CIVIL DIVISION
No. 03-5544 CIVIL TERM
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
Defendants, BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA
Garnishee.
Defendant's Address:
132 EAST LIBERTY AVENUE
CARLISLE, PA 17013
Garnishee's Address:
22 S. HANOVER STREET
CARLISLE, PA 17013
Date: JULY 19, 2006
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
LORI M. DIRENZO, ESQ.
PA ID NO. 201843
AMY L. SABOLCHICK, ESQ.
PA ID NO. 94653
ANNA M. BONARRIGO, ESQ.
PA ID NO. 202070
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4`h Floor
Canonsburg, PA 15317
(724) 916-2400
J, 16
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE COMPANY OF
PENNSYLVANIA,
Plaintiff,
vs.
DONALD A. SHEETZ and
SHIRLEY M. SHEETZ,
and
Defendants,
ORRSTOWN BANK,
Garnishee.
CIVIL DIVISION
No. 03-5544 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 DONALD A. SHEETZ and SHIRLEY M. SHEETZ, defendants, and
3. against ORRSTOWN BANK, garnishee,
4. and index this writ
a. against DONALD A. SHEETZ and SHIRLEY M. SHEETZ, defendants, and
b. against ORRSTOWN BANK, garnishee, and any property of the defendants in
the name of Garnishee:
Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual
and joint, personal and business
5. Amount of Judgment
Additional Interest to Date
Less Payments Made
(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.
$7,357.061'7'7'( - 33
$1,054.05
(5,585.73)
$2,8 . 8
CATHY CHR MUZAK, ESQ.
LORI M. IRENZO, ESQ.
AMY L. SABOLCHICK, ESQ.
ANNA M. BONARRIGL, ESQ.
t
m
n
G
Z,
?t
? ? ? ° c C C C ? ? ? Q
J 1
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5544 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY
DB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA, Plaintiff (s)
From DONALD A. SHEETZ AND SHIRLEY M. SHEETZ, 132 EAST LIBERTY AVENUE,
CARLISLE, PA 17013
(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 ORRSTOWN BANK, 22 S. HANOVER 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 $1771.33
Interest TO DATE - $1,054.05
Atty's Comm %
Atty Paid $231.10
Plaintiff Paid
Date: JULY 24, 2006
(Seal)
REQUESTING PARTY:
L.L.
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothonotary
By:
Deputy
Name AMY L. SABOLCHICK, ESQUIRE
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. 94653
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-05544 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT C
VS
SHEETZ DONALD A ET AL
And now VALARIE WEARY Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0008:30 Hours, on the 31st day of July , 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
SHEETZ DONALD A
, in the
hands, possession, or control of the within named Garnishee
ORRSTOWN BANK 22 SOUTH HANOVER ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
CARRIE MCGEE (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 fe ?-ao
Affidavit .00 R: Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
OO r i-1To(.
08/03/206
Sworn and Subscribed to
before me this day of By
Deputy thg?iff
A.D
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-05544 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT C
VS
SHEETZ DONALD A ET AL
And now VALERIE WEARY
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0008:30 Hours, on the 31st day of July , 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
SHEETZ SHIRLEY M in the
hands, possession, or control of the within named Garnishee
ORRSTOWN BANK 22 SOUTH HANOVER ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
CARRIE MCGEE (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 answeU.-,Af
Docketing .00?
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
00
J 5 -14 oL.,.
08/03/2006
Sworn and Subscribed to
before me this day of By ?'? " /?
Deputy Sheri -If
A.D
t
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CDC d/b/a CIVIL DIVISION
BENEFICIAL MORTGAGE
COMPANY OF PA, No. 03-5544
TYPE OF PLEADING:
Defendants. Civil Action
FILED ON BEHALF OF:
vs.
Plaintiff,
Praecipe to Satisfy Judgment
DONALD A. SHEETZ and
SHIRLEY M. SHEETZ, TYPE OF CASE:
BENEFICIAL CDC d/b/a
Plaintiff's Address: BENEFICIAL MORTGAGE
2700 Sanders Road COMPANY OF PA
Prospect Heights, IL 60070
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
AMY L. SABOLCHICK, ESQ.
PA ID NO. 94653
ANNA M. BONARRIGO, ESQ.
PA ID NO. 202070
CHROMULAK & 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.
U -
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CDC d/b/a
BENEFICIAL MORTGAGE
COMPANY OF PA,
Plaintiff,
VS.
DONALD A. SHEETZ and
SHIRLEY M. SHEETZ,
Defendants.
CIVIL DIVISION
No. 03-5544
PRAECIPE TO SATISFY JUDGMENT
TOPROTHONOTARY:
Please satisfy the judgment against DONALD A. SHEETZ and SHIRLEY M. SHEETZ,
at No. 03-5544, and mark the docket accordingly.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By: v
CATHY ANN CHRO LAK, ESQ.
PA ID NO. 42067
AMY L. SABOLCHICK, ESQ.
PA ID NO. 94653
ANNA M. BONARRIGO, ESQ.
PA ID NO. 202070
Attorneys for Plaintiff
375 Southpointe Boulevard
4t' Floor
Canonsburg, PA 15317
Sworn to and s
Before me this
of
Notary
i day
2006.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seel
Hesttter L Hatfield, Notary Public
Cecil Twp., Washhoon Cou *
My Commission Expires June 29, 2010
Member, Pennsvivania
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 CDC d/b/a BENEFICIAL MORTGAGE COMPANY OF PA,
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 29TH day of
SEPTEMBER, 2006.
DONALD A. SHEETZ and
SHIRLEY M. SHEETZ
132 E. LIBERTY AVENUE
CARLISLE, PA 17013
Cathy Ann Chromulak, Esq.
Amy L. Sabolchick, Esq.
Anna M. Bonarrigo, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
r?-?
t"7?_-?,, -rti
{^ ? ? ?
`rte c"7 ?-?? c-.
? .jam;
? ??' ?.
-_}
Ti ': i.
.,,: , a..i ? ??'r
Sheriff tp? e g ¢1 Woccording to law, states this
R. Thomas Kline,
Writ is returned ABANDONED, no action taken' n six months.
Sheriff's Costs: 1006 JUL 28 `a 8' 4U Advance Costs: 150.00
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
TOTAL
Sheriff's Costs 98.74
18.00 51.26
1.94
1.00 Refunded to Atty on 04/27/07
8.80
40.00
20.00
9.00
98.74 ? s?a y?o 9-
So Answers; Fla- c
V
1
R. Thomas Kline, Sheriff
Byo
65 Ty
/ q3 3o3
£0t* 'ox (1I unoD auiazdnS
OObZ-9I6-t,ZL :ouogdPjo L
33I.LAIIV'Id :xol Aau.[ouv
LL£SI'vd `f)HflgsN0NV3
w00'I3 Hjy
GWAd'IfIOg d.LNIOdH.LfIOS SL£
I?OSS?'Y XV'IfIIVOHH0 :ssaJPPV
HHlaaSd `?IOIH:)ZOgVS "I ALA' aIlutN
A.L2Idd JNIZSgfldg2I
AlndaQ
:Ag
,CJMOuoilold
ONO'I Id SI.LWaD
slsoD zaglO
00. is fglozd ana
(IrgS)
9002 `I'Z Aquu :alr(I
PTrd iPUPIld
Oi'I£ZS Pird Xuv
% uuuOO S,A:p ,'
SO'Psols - H.LVQ OZ Isazalul
££'ILLIS anQ lunouid
•palrls anogr st, pou!ofua si pur oagsiuieii
r sr pappr uaaq srq aqs/ai Isgl zaq/Lu.4 Xjpou of paloaiip ajr noA `aagsnue9 pauxeu r urgl iailo ouoAur3o
uoissossod agl ui punoj si luauulorllr of loafgns ur uodn patAal lou (s)lut,pualap agl3o ,Clzadozd3I (£)
`.3oazagl Suisodsip asimimpo io (s)
lurpua3ap aql jo A413doid Cur -guizaAtlap LUOIIJ pue (s) Iuepua3ap ail Io lunoooe ail io3 zo of Igap Cur Sul ied
tuog pauiofua si (s)aagsiuteS aql (q) 'ponssi uaaq seg luauzgor;lr ur (e) :Irgl (s)aagstutri? aql Xjjjou of pule
:SM01103 st, (S)dgHSIN vq
ssaNisflg (INV
'IVN0SHHd `lKIOf (INV 'IdfIQIAI(IKI `S,LNfIO33d ANY NJ .LNVaNH3aQ WIG SaINO W
'I'II OZ LI?Idf1S2Ifld - £IOLI dd `?'ISI'RI?? `'ZS 2IdA0I?I?H'S ZZ `}I g I?IMOLS2I?IO JO
uocssassod aql ui uodn patAal IOU (s)Iuepuajap agl3o Xuadozd ail goellt, of paloaup osle air noA (Z)
Ilas of pue(s) luepua;ap ailIo 6 iadoid agl uodn XAol of poloanp aze noA (I)
£IOLI dd `a'ISI'MVJ
`3flNgAV A.LHagI'I .LSVH Z£i `Z1.aaHS 'ICI AT IIHS QAIV Z.LaaHS 'V Q'IVN0G uxo13
(s) JJ!lulvld `VINVA'IASNN21d 90 ANVdWO3 HOVO.LIIOW 'IVIJIAaNa*l d/g/Q
ANVjWoa .LNfIODSIQ -daW ISNloj 'IVI31AHN:lg onp s;soo put, Isaialui `Igap agl fjstles o,l,
:AZNf10O GNV'M3ff 1IfID 30 ddRIdHS MI OZ
Md'I - NOLLOV IIAIO WNWINgE WIO 3O A.LNIIOD
I!A!a t VSS-£0 ON (VINVA'IASNNdd 10 H.L'IddMNOY WO3