HomeMy WebLinkAbout03-5853IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
CREDIT SERVICES,
CIVIL DIVISION
No. 03 - S*O C,3
Plaintiff,
VS.
GEORGE W. MANUAL aka GEORGE W.
MANUAL JR.
and
THELMA J. MANUAL
Defendants.
Plaintiffs Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
430 North Pitt Street
Carlisle, PA 17013
DATE: [\ ePY bFr &, 2o3
TYPE OF PLEADING:
Complaint
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES
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
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
CREDIT SERVICES
Plaintiff, CIVIL DIVISION
Vs.
No.
GEORGE W. MANUAL aka
GEORGE W. MANUAL JR.
and THELMA J. MANUAL
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
CREDIT SERVICES,
Plaintiff,
vs.
CIVIL DIVISION
No. C 3 - S'PS'3 (1
GEORGE W. MANUAL aka
GEORGE W. MANUAL JR.
and
THELMA J. MANUAL,
Defendants.
COMPLAINT
AND NOW COMES, the Plaintiff, BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT SERVICES, 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
CREDIT SERVICES 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. GEORGE W. MANUAL aka GEORGE W. MANUAL JR. and THELMA J.
MANUAL are adult individuals residing at 430 North Pitt Street, Carlisle, PA 17013.
3. On or about November 2, 1998, 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 18 AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
5. Defendants are in default under the terms and conditions of the aforementioned
Loan Agreement for failing to make payments when due, with the last payment having been
made on or about October 16, 2000.
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 One Thousand, Two Hundred Seventy-Five and 31/100 ($1,275.31)
Dollars as of September 24, 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 One Thousand, Two Hundred
Seventy-Five and 31/100 ($1,275.31) Dollars, plus court costs and attorney's fees.
Respectfully submitted,
Mollica & Chromulak
By:
DATE: November & q-603 CATHY ANN HROMULAK, 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.
09/10/09 WED 21:21 FAX 717 249 9424 BENEFICIAL CARLISLE - R002
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aaBt W 0: ymdY kk.: toxtym: ':' .. +.:'.: ;'. ,,: • :M arm yma 6duIF _ : afyr you hat made a9 ...... an meda, indldinp year.
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:.. 'Bar prawn ahodck WIN hw sonoM You art OW A {apldtY in*M in the goods gou'we purduwiap•
. lad a.r.a ' ensure am tau Oh r IF va rr" lil'h'akYhait 10 drys er more after Ww data it h due, we ibd clang. you w ate
?.a d prfcm m ow . ahvgto[ 1N lesarpf BA of .Ilan.M.M*nd ar i5.OG, but not lees; than 91AO., . .
'? S ?? O? aeewa soft E P1°WYm°Y IfyW'IIOY o9lgrlyr nod; way h¦ emitldd°to'i refia?`of poi drum Rdenee'GMiga.' -
see the AV" far addiBaml kfartOne about amputation, dctadl wry requited apryma k tug before
Q tlk sdadakd data and pmpoyout I IUMS. ,
'- "d' ?? ?' 1(/ ? B wuaa a r0ume Yb' wadap Ike paymha der data a your fuel Payment wN but do 30 days after dclary
1 j1 at . .. Ir of Ea Back and you. mm make ad mho patmow an the an day of each month grafla.
110112 TO THE BUYER: 1. 00 NOT SIGN TOM ADBEEIAEYT BEFORE YOU BEAD IT {OAR IF IT CONDIIBS ANY MANN SPACS8. Z. YOU ARE eYTtna WRLEFEL DUE AND BIDER YURNN CO MILS'M THIS OB AGREEMENT.
PAIMAL RIFUMOE TBE SFABICEE CHARGTHE 6010ANCEY OCNAF M DYANCE THE FULL AMOUNT
?..rrn J/ . ?ivt t • "x
NoBm of mmitatim No 11 , L/ S
You m?aYY CANCq. Mb trenagUee, with Of amt P
OABpadaa, whbM THREE BUSINESS BAYS Ram i
mNN?dtwago FEW Bflr?d gays emcrrmo
t?adaMg gm w ?waD:ra? ?bd/cepmNae.? secodpr
gnat Few moat wb auaoradg in Me seer at your
ta, a ubmntw As C", asndtdoo as WAVA reedaed, any
daBeered fo yao andr oshaaf or ate; or tar may, H
so. amply with the fidons d the sear regaranpy Me
ahipman[ d fba-B der at the segues aapaso and dsk
do erupt Ms dateda ayeWme to the Regur atW the author dos
W. or It gem to Mum the goods to MO Solar sad IsH to
do a, gam y6m rwmshr Raba tr pedorakace of ay fibagagoos
rear too cenbact.
So aped We wabe w*ff,-m#N or deliver a signed and dated copy
of this pnabamw N or any door wrFUa aoSce, or sad a
faaga
TpattTCr6rr e
to
Nedra at Wnuenalfoo A/C t +,` S
You may CANCEL to fmnsadign. without stay Papally or
""I'M on, wftn THREE BUSINESS LAYS from fate above date.
It you carted, guy pmparq coded to. any pg)ymints made by you
under the emh at or saie, and say megadaba Wronger exoated
by Flu wit be returned within T BUSINESS BAYS teOoMng
rasdpt by the sage/ of your moveBadan Mateo, and any samriry
interest ads" out of tbo hagachoo wo be worosad.
It tee coned, you must make mabble to Me Solar at your
reaidana, in mbmngiby as band anndUbn as when received, any
goods denvued to you under tats contract or cab; or you may, IF
on orlon, want hYM Ma tfiaWctifins ai the Septa ropardiapp the
Aware mpmaM gift goods ar the 4P a apanre and dsk.
If you do make Meqm de aa/bbb to the NOW and the Satyr does
fiat plak dam up WOnet 20 days of the data of your Netlro of
Waft a, you may refsia or atte m of the goads without any
former dmpaUoH. If you ISU to make the gads sayable to ft
Seller or H yna agree to refum the goods to the Super and /aU to
do so, then yon remain Noble for pedonst of at obggadas
Under fee Canlrer.
m cannot this Uvasactbn, mab or de0rr a signed and dated may
of thir dancdfatinn Notice or any other wrdlsd an&@, or send a
neap.
ro F1'? 1 ?Sr?-'(6r?'v6 r?
f ogl»c3 CGlar.'wh ?a (? u
at
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Na ad and W hay the fang Seeds codger bltakac .
Dmwlp&a of Gods ahdler Servlca - Mandadmair Model No, Serial Na _ Cash Selo Pries
,I, J { S 12.00.00
:Ytn,.?lll.. I ?9YQS'U0713S' ) Ice
Pa Muted Cadbury Oats: ... Sala Ta.3 7a-o0
0 BNPA 1me BUM $BE MIR RIDE FOR IMPORTANT INFORNUTION AP N We (5t), td. area
BENEFICIAL CARLISLE Z003
09/1101,03 WED 21:22 PAX 717 249 9424
Proposal tcPay. Yap yrmdan to pay that Total of Rrymm tt occmdmg to
par payment rJwddk' shown an the Irmt tit this Apmmmlt.
$mMty: To pmmot. we and to make TOto we men paymrytt m thk
Awamn You vIm is a percbw nrdmy oathlty lei=' vital Baods you
.m plpdmeog. If par do cat poem your obligation ?uAer Uds A6rmmom,
ym mky lose Ike goods You arc pmbulno under the Agreement; ,
rate Charger If we M ON an kww ow 14 trop or mom Bite Um data II
IndrA rya a Smogs top a hu dredge OOL Ipeiw of fi% ol?We?.
kmrdmem or dSO4 kut not Ire: rids d1Aa
Popular fo' Adeurx YOe may any molecule ywppll'gwa at any
Une• tl yin prepay in NA 'we WEI r& W my ®emeed Fromm Chmpa uskso
Uw Aenrmlei Daily Refine Method. We mod ma nuke any ROM Camps
rmmd m kg than41.24.
DdamC Ym we in daleldi H you tap Ill make any Postpone when It tomes
due
Am,maradoo of PpYmema: If You default. wo an demand kmmodfiale
gaymem of the mare moron you on. H you ransin in detect 21 days
shol ou meow the rlgbl to revs miles required by law, and outlets In My
MmM owed to you, fipund In the same way as N you had made peymem N
0dyor;e Tkk am; is not required in be pmuWod more that once In any
hwhte month pmPod, . .
Law AppOwelpe: Nonsylvanls low,garam this Agreement.
ADdvaoy] Foe; If we pin side Agreement to an attamW Dal our seladed'
W$kYoel far ca moor, the PmeaBmp party shag pay reasonable mlmpeys
ice mW men oasts,
Imacsi After Mamdty: Ater maturity of gds Aprmnam, You ahalf pay
Wallace at the mm of 6% per Yam m amt apwd balms pf the Total m
Part".
Amlipmant It Is erpcred that Sagan will assign this Agreement to
Ben'aed Credo Smrti m without further At natico to you. Upan
assignment, all of Seller's rights honunder wB tra sferto Banepcial Cradle
6mviucs as Mount. , .. .
Cmditwortbinaam Even though signed by us, our rural accemanne of this .
Agnpmenl is continuum OAR spur creditworthiness.
You trophy oulhobot and Instruct awfew Crada Smkces SICS) W OF" and naive medl elwmtion about you been any aedt reporting agony or thud pars,
INSTRUCTIONS TO BCS TO PROVIDE CREDIT INFORMATION
BCS is ellNsted with actor Bene&kl COWNOm 1"AHDMal, While you understand that the following authorization and instruction is nat a
to". to yRiffy for on AeouK In ardor that you may bare about Ike andit'or Wells atferialp; of ANiliatus or their agents, you oudmrin
aM bnvmt BCS to provide to AfBWm or !hair AWm, any credit Idormtko about yea that yen ban provided on par application m that BCS
ubmBi from amy credit mportRng agency m third , pony, lku undersland that II you W not wool to omher4o and instruct BCS tC provide such audit
Inlamadon to ANNatu At thek plants, you may advise SCS by calling roll•Irn at 1-001WFU41. Develo ; " available 8A0 AM to 8:00 PM Eostom time,
To ooeme that an such moil information is prodded to ANllieta or rook again, you shoAd so within 10 nlwrdw days olur the data of this AgruumCnt. 8CS
the B appki to provide inch ands fnt radon to AHBmm or thek people N you do or toll within them 10 days. At am( dine thereafter however, you may old
Von a n of such credit Mormamn to pirNates or ton agent. However. ust, dwu call.
To Bmay male one sufrdnitbo ohw hudeen
thft on W in a OWN month ypu to
ANY HOLDEN OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WNICH THE DEBTOR COULD ASSERT
AGAINST THE $ELLEN OF OGOpS ON SERVICES OMMED PURSUANT HERETO, 119 WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE
DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY TOE DERTDR MEREUNDIR
The pk N cmw wd In this bog Is net pmt m site Stanley Agreement
ASSIGNMENT
For yA m resolved, Ike w de zk* aside itch Alp mat ao: 0 BENEFICIAL CDHSIIArER WSCOUNT COMPAHy
doh BemTWht Claris Senkn
0 BENEFICIAL
ad.
AIAfJL,/
By
SEP 16 2003 1327 FR MOLLTCA AND MURRRY 4123817111 TO 8510269000009175 P.02/02
VEIZIFICATION
I, Patricia Garcia, Recovery Specialist for
BENESICIAL CONSUMER DISCOUNT COMPANY, A HOUSEHOLD INTERNATIONAL COMPANY
verify that the facts set forth in the foregoing Complaint are true and correct to the best of my
knowledge, information and belief, and that I am authorized to verify such Complaint on behalf
of BENLVICIAL
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904
relating to unworn falsification to authorities.
Petri Garcia
Dated: 11-03-03
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
CREDIT SERVICES,
Plaintiff,
vs.
GEORGE W. MANUAL a/k/a
GEORGE W. MANUAL,JR., and
THELMA J. MANUAL,
Defendants
Defendants' Address:
430 North Pitt Street
Carlisle, PA 17013
CIVIL DIVISION
No. 03-5853 Civil Term
TYPE OF PLEADING:
Acceptance of Service
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
CREDIT SERVICES
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
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
CREDIT SERVICES,
Plaintiff,
vs.
GEORGE W. MANUAL a/k/a
GEORGE MANAUAL JR. and
THELMA J. MANUAL,
Defendants.
CIVIL DIVISION
No. 03-5853 Civil Term
ACCEPTANCE OF SERVICE
George W
Manual a/k/a George W
Date:
Date: j i zq 03
We accept service of the Complaint on behalf of ourselves,
Manual, Jr. and Thelma J. Manual.
e rg W. Manual a/k/a
orge W. Manual, Jr.
430 North Pitt Street
Carlisle, PA 17013
?-G{LE?Ct'ta ? ? / l` / ? ? t ?a 0
Thelma J. Manual
430 North Pitt Street
Carlisle, PA 17013
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
CREDIT SERVICES,
VS.
GEORGE W. MANUAL
aka GEORGE MANUAL and
THELMA J. MANUAL,
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
430 NORTH PITT STREET
CARLISLE, PA 17013
Plaintiff,
Defendant.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CIVIL DIVISION
No. 03-5853
TYPE OF PLEADING:
Praecipe to Reinstate Complaint
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES
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 CIVIL DIVISION
CREDIT SERVICES,
Plaintiff,
No. 03-5853
VS.
GEORGE W. MANUAL aka
GEORGE MANUAL and
THELMA J. MANUAL,
Defendant.
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the complaint in the above-captioned action, at 03-5853 and mark the
docket accordingly.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
BY"Zg& g e&tatO,
CATHY ANN CHR MULAK, ESQ.
SCOTT E. CRAWFORD, ESQ.
MOLLICA & CHROMULAK
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211
(412) 381-7000
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THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
CREDIT SERVICES,
CIVIL DIVISION
No. 03-5853 -Civil Term
Plaintiff,
VS.
TYPE OF PLEADING:
GEORGE W. MANUAL a/k/a.
GEORGE W. MANUAL, JR.
and THELMA J. MANUAL,
Defendants.
Praecipe for Entry and
Withdrawal of Appearances
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
SCOTT E. CRAWFORD, ESQ.
PA ID NO. 89570
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4`h Floor
Canonsburg, PA 15317
(724) 916-2400
THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
CREDIT SERVICES,
CIVIL DIVISION
No. 03-5853 - Civil Term
Plaintiff,
vs.
GEORGE W. MANUAL a/k/a.
GEORGE W. MANUAL, JR. and
THELMA J. MANUAL,
Defendants.
PRAECIPE FOR ENTRY AND WITHDRAWAL OF APPEARANCES
TO PROTHONOTARY:
Please enter our appearance on behalf of Plaintiff, BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT SERVICES.
CATHY ANN CHR ULAK, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
SCOTT E. CRAWFORD, ESQUIRE
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
Please withdraw the appearance of Mollica & Chromulak as counsel for BENEFICIAL
CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL CREDIT SERVICE
CATHY ANN CHROMULAK, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
SCOTT E. CRAWFORD, ESQUIRE
MOLLICA & CHROMULAK
450 Trimont Plaza
1305 Grandview Avenue
Pitttsburgh, PA 15211
(412) 390-7000
CERTIFICATE OF SERVICE
I, Scott E. Crawford, Esquire, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY
d/b/a BENEFICIAL CREDIT SERVICES, hereby certify that a true and correct copy of the foregoing
Praecipe for Ap earance served upon the following by First Class Mail, postage prepaid on this
day of AM 044nK 2004:
GEORGE W. MANUAL a/k/a
GEORGE W. MANUAL, JR. and
THELMA J. MANUAL
30 NORTH PITT STREET
CARLISLE, PA 17013
a/ y6G"v'1 4
Scott E. Crawford, Esquire
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES,
Plaintiff,
vs.
GEORGE W. MANUAL a/k/a GEORGE
W. MANUAL, JR. and THELMA J.
MANUAL,
Defendants.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendants' Address:
430 NORTH PITT STREET
CARLISLE, PA 17013
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CIVIL DIVISION
No. 03-5853 CIVIL TERM
TYPE OF PLEADING:
Consent To Judgment
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
SCOTT E. CRAWFORD, ESQ.
PAID NO. 89570
CHROMULAK do ASSOCIATES, LLC
375 Southpointe Blvd.
4a' Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES,
Plaintiff,
VS.
GEORGE W. MANUAL a/k/a
GEORGE W. MANUAL, JR. and
THELMA J. MANUAL,
Defendants.
CIVIL DIVISION
No. 03-5853 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 CREDIT SERVICES and against Defendants, GEORGE W.
MANUAL a/k/a GEORGE W. MANUAL, JR. and THELMA J. MANUAL, in the amount of
ONE THOUSAND SEVEN HUNDRED THIRTY-NINE AND 81/100 ($1,739.81), with interest
thereon at the legal rate of 6% from DECEMBER 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,
CHROMULAK & ASSOCIATES, LLC
By: ??4
Scott E. Crawford, Esq.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT CIVIL DIVISION
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES, No. 03-5853 CIVIL TERM
Vs. Plaintiff,
GEORGE W. MANUAL a/k/a GEORGE
W. MANUAL, JR. and THELMA J.
Defendants.
CONSENT TO JUDGMENT
AND NOW, to wit, this 19 `t & day of jOIMUL&IV"? 200 with the
consent of all parties and their respective counsel, it is agreed as follows:
Judgment shall be and is hereby entered against Defendants GEORGE W. MANUAL
a/k/a GEORGE W. MANUAL, JR. and THELMA J. MANUAL in the amount of ONE
THOUSAND SEVEN HUNDRED THIRTY-NINE AND 81/100 ($1,739.81) DOLLARS
plus interest on the unpaid balance at the rate of 6% per annum commencing on
DECEMBER 3, 2003.
2. Defendants GEORGE W. MANUAL a/k/a GEORGE W. MANUAL, JR. and THELMA
J. MANUAL agree to make payments to Plaintiff BENEFICIAL CONSUMER
DISCOUNT COMPANY d/b/a BENEFICIAL CREDIT SERVICES as follows:
Payments of Fifty and 00/100 ($50.00) Dollars in the months of January and February
2004, and then monthly payments of One hundred and 00/100 ($100.00) Dollars
beginning March 2004 until the debt is paid in full. The payments must be received on or
before the 10th day of each month. The first payment shall be due on or before
JANUARY 10, 2003.
Payments shall be sent to Plaintiff BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT SERVICES 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
CREDIT SERVICES may later designate.
4. Defendants GEORGE W. MANUAL a/k/a GEORGE W. MANUAL, JR. and
THELMA J. MANUAL have induced Plaintiff BENEFICIAL CONSUMER
DISCOUNT COMPANY d/b/a BENEFICIAL CREDIT SERVICES, and Plaintiff
BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL CREDIT
SERVICES agrees to forbear in the enforcement of its rights against him/her so long
as Defendants GEORGE W. MANUAL a/k/a GEORGE W. MANUAL, JR. and
THELMA J. MANUAL make timely payments. If Defendants GEORGE W.
MANUAL a/k/a GEORGE W. MANUAL, JR. and THELMA J. MANUAL fail to
make timely payment, then Plaintiff BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT SERVICES may institute or take all steps
necessary, appropriate or helpful to collect the judgment, represented hereby, together
with the Plaintiffs costs of collection and attorneys fees therefore.
ritten above, the parties set forth their hands and seals as follows:
W. MANUYkIa GEORGE
JAL, JR.
Witness
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CN 4.xNA; 11?
THELMA J. ANUAL
: lj ?l?
Scott E. Crawford, Att ey for Plaintiff
CERTIFICATE OF SERVICE
I, Scott E. Crawford, Esquire, counsel for Beneficial Consumer Discount Company,
hereby certify that a true and correct copy of the foregoing Praecipe for Entry of Consent to
Judgment served upon the following by First Class Mail, postage prepaid on this 19th day of
January, 2004:
GEORGE W. MANUAL
THELMA MANUAL
430 NORTH PITT STREET
CARLISLE, PA 17013
Scott E. Crawford, Esquire
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
PS ? ? '
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY d/b/a
BENEFICIAL CREDIT SERVICES,
Plaintiff,
CIVIL DIVISION
No. 03-5853 CIVIL TERM
vs.
GEORGE W. MANUAL
a.k.a. GEORGE W. MANUAL, JR.
and
THELMA J. MANUAL,
Defendants,
and
MEMBERS 1 ST
FEDERAL CREDIT UNION,
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendants' Address:
430 NORTH PITT STREET
CARLISLE, PA 17013
Garnishee's Address:
1000 BRYN MAWR ROAD
CARLISLE, PA 17013
Date: April 21, 2004
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
SCOTT E. CRAWFORD, ESQ.
PA ID NO. 89570
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4"' Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY d/b/a
BENEFICIAL CREDIT SERVICES,
Plaintiff,
VS.
CIVIL DIVISION
No. 03-5853 CIVIL TERM
GEORGE W. MANUAL
a.k.a. GEORGE W. MANUAL, JR.
and
THELMA J. MANUAL,
Defendants,
and
MEMBERS 1ST
FEDERAL CREDIT UNION,
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 GEORGE W. MANUAL a.k.a. GEORGE W. MANUAL, JR., defendant, and
3. against THELMA J. MANUAL, defendant, and
4. against MEMBERS 1 ST FEDERAL CREDIT UNION, garnishee,
5. and index this writ
a. against GEORGE W. MANUAL a.k.a. GEORGE W. MANUAL, JR., defendant,
and
b. against THELMA J. MANUAL, defendant, and
c. against MEMBERS 1ST FEDERAL CREDIT UNION, garnishee, and any
property of the defendant in the name of Garnishee:
Said Writ of Execution is pursuant to all monies due defendants in any accounts, individual and
joint, personal and business.
6. Amount of Judgment
Additional Interest to Date
Less Payments Made
(Costs to be added)
$1,739.81
$ 37.32
$ (150.00)
Pursuant to Writ of Execution
And Service of Writ
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
ee ncen me rUAr ennn^0=
$1,627.13
SCOTT E. CRA ORD, ESQ.
I
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5853 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 CREDIT SERVICES, Plaintiff (s)
From GEORGE W. MANUEL A.K.S GEORGE W. MANUAL, JR. AND THELMA J. MANUAL
430 NORTH PITT STREET, 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 MEMBERS 1sT FEDERAL CREDIT UNION, 1000 BRYN MAWR ROAD, CARLISLE, PA 17013
- ANY PROPERTY OF THE DEFENDANT IN THE NAME OF GARNISHEE
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 $1,627.13 L.L. $.50
Interest TO DATE - $37.32
Atty's Comm % Due Prothy $1.00
Atty Paid $82.00 Other Costs $.50 DUE GARNISHEE
Plaintiff Paid
Date: APRIL 23, 2004
CURTIS R. LONG
Prothonot ry
(Seal) ? By: o-),•
Deputy
REQUESTING PARTY:
Name SCOTT E. CRAWFORD, 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. 89570
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-05853 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
MANUAL GEORGE W ET AL
And now RONALD HOOVER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0016:23 Hours, on the 30th day of April , 2004, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
MANUEL GEORGE W AKS GEORGE W. MANUEL JR in the
hands, possession, or control of the within named Garnishee
MEMBERS 1ST FEDERAL CREDIT UNION
1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
LUANNE KYLE (ASST. 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 ans
Docketing .00'•? r
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
00
00/00/0000
Sworn and subscribed to before me
By
this Z day of Deputy Sheriff
A4vayO A..1D...??/?+ y
Prothonotary 4y ?? V
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-05853 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
MANUAL GEORGE W ET AL
And now RONALD HOOVER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0016:23 Hours, on the 30th day of April , 2004, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
MANUEL THELMA J in the
hands, possession, or control of the within named Garnishee
MEMBERS 1ST FEDERAL CREDIT UNION
1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
LUANNE KYLE (ASST. 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 an
Docketing .00 Service .00
Affidavit .00 R. Thomas Kline =
Surcharge .00 Sheriff of Cumberland County
.00
00
00/00/0000
Sworn and subscribed to before me
By
this T3 ?" day of Deputy Sheriff
a? A.D.
0- r. Af
Prothonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES,
Plaintiff,
VS.
GEORGE W. MANUAL aka GEORGE
W. MANUAL, JR. and THELMA J.
MANUAL,
and
Defendants,
MEMBERS I ST CREDIT UNION,
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
THIS 15 AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CIVIL DIVISION
No. 03-5853 CIVIL TERM
TYPE OF PLEADING:
Praecipe to Settle and
Discontinue Against Garnishee
ONLY
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
SCOTT E. CRAWFORD, ESQ.
PAID NO. 89570
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
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES,
Plaintiff,
VS.
GEORGE W. MANUAL a.k.a
GEORGE W. MANUAL, JR. and
THELMA J. MANUAL,
Defendants,
and
MEMBERS 1 ST CREDIT UNION,
Garnishee.
CIVIL DIVISION
No. 03-5853 CIVIL TERM
PRAECIPE TO SETTLE AND DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
Please settle and discontinue this action against the above garnishee, MEMBERS 1 ST
CREDIT UNION and mark the docket accordingly.
Sworn to and subscribed
Before me this /7M day
of, 2004.
A^'e
otary Public
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By:/yG
CATHY ANN CHROMULAK, ESQUIRE
SCOTT E. CRAWFORD, 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, Scott E. Crawford, Esquire, counsel for BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT SERVICES, hereby certify that a true and correct
copy of the foregoing Praecipe to Settle and Discontinue Against Garnishee Only was served
upon the following by First Class Mail, postage prepaid on this 17th day of May, 2004.
MEMBERS 1 ST CREDIT UNION
P.O. BOX 40
MECHANICSBURG, PA 17055
GEORGE W. MANUAL aka
GEORGE W. MANUAL, JR. and
THELMA J. MANUAL
430RTH PITT STREET
CARLISLE, PA 17013
I
V
Scott E. Crawford, Esq.
Dated: May 17, 2004
EB THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
IFORMATION OBTAINED WILL
E USED FOR THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY dlbla
BENEFICIAL CREDIT SERVICES,
Plaintiff,
CIVIL DIVISION
No. 03-5853 CIVIL TERM
vs.
GEORGE W. MANUAL
aka, GEORGE W. MANUAL, JR.
and
THELMA I. MANUAL,
Defendants,
and
MEMBERS IST,
FEDERAL CREDIT UNION,
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendants' Address:
430 NORTH PITT STREET
CARLISLE, PA 17013
Garnishee's Address:
1000 BRYN MAWR ROAD
CARLISLE, PA 17013
Date: January 31, 2005
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY dlbta BENEFICIAL CREDIT
SERVICES
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MELISSA A. SHENKEL, ESQ.
PA ID NO. 91445
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4rh Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER
DISCOUNT COMPANY d/b/a
BENEFICIAL CREDIT SERVICES,
Plaintiff,
vs.
CIVIL DIVISION
No. 03-5853 CIVIL TERM
GEORGE W. MANUAL
a.k.a. GEORGE W. MANUAL, JR.
and
THELMA J. MANUAL,
Defendants,
and
MEMBERS 1ST'
FEDERAL CREDIT UNION,
Garnishee.
PRAECIPE FOR WRIT OF EXECUTION
TO: The Prothonotary
Please issue a Wrlt of Execution in the above matter,
1. directed to the Sheriff of CUMBERLAND County;
2, against GEORGE W. MANUAL a.k.a. GEORGE W. MANUAL, JR., defendant, and
3. against THELMA J. MANUAL, defendant, and
4. against MEMBERS 1 ST FEDERAL CREDIT UNION, garnishee,
and index this writ
a. against GEORGE W. MANUAL a.k.a. GEORGE W. MANUAL, JR., defendant,
and
b. against THELMA J. MANUAL, defendant, and
c. against MEMBERS I ST FEDERAL CREDIT UNION, garnishee, and any
property of the defendant in the name of Garnishee:
Said Writ of Execution is pursuant to all monies due defendants in any accounts, individual and
ioint, personal and business.
6. Amount of Judgment
Additional Interest to Date
Less Payments Made
(CostsIto be added)
$1,739,81
$ 282.46
$ (474.00)
Pursuant to Writ of Execution
And Service of Writ
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
$1,548.27
AELISSA7t-A. < A?
SHE KEL, ESQ.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5853 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY
DIB/A BENEFICIAL CREDIT SERVICES, Plaintiff (s)
From GEORGE W. MANUAL A/K)A GEORGE W. MANUAL, JR. AND THELMA J.
MANUAL, 430 NORTH PITT STREET, CARLISLE, PA 17013
(I) 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 MEMBERS I" FEDERAL CREDIT UNION, 1000 BRYN MAWR ROAD, CARLISLE, PA
17013 - PURSUANT TO ALL MONIES DUE DEFENDANTS 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 gal nishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
AmountDue $1,265.81 L.L. $.50
Interest TO DATE $282.46
Atty's Comm % Due Prothy $1.00
Atty Paid $99.50 Other Costs
Plaintiff Paid
Date: FEBRUARY 3, 2005
CURTIS R. LONG
Prothonota
(Seal) <By:/L?
Deputy
REQUESTING PARTY:
Name MELISSA A. SHENKEL, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L. C.
375 SOUTHPOINTE BOULEVARD
4"' 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, PENNS-'LVANIA
BENEFICIAL CONSUMER DISCOUNT CIVIL DIVISION
COMPANY dJb/a BENEFICIAL CREDIT
SERVICES, No. 03-5853 CIVIL TERM
Plaintiff,
VS. TYPE OF PLEADING:
Praecipe to Discontinue
GEORGE W. MANUAL a/k/a GEORGE Against Garnishee ONLY
W. MANUAL, JR. and THELMA
MANUAL, TYPE OF CASE:
Defendants, Civil Action
and
FILED ON BEHALF OF:
MEMBERS 1ST FEDERAL CREDIT
UNION, BENEFICIAL CONSUMER DI COUNT
Garnishee. COMPANY d/b/a BENEFICIAL CREDIT
SERVICES
Plaintiffs Address: COUNSEL OF RECORD:
2700 Sanders Road
Prospect Heights,., IL 60070 CATHY ANN CHROMULA ESQ.
PA ID NO. 42067
MELISSA A. SHENKEL, ESQ
PA ID NO. 91445
CHROMULAK & ASSOCIATtS, 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
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES,
Plaintiff,
VS.
GEORGE W. MANUAL a/k/a GEORGE
W. MANUAL, JR. and THELMA MANUAL,
Defendants,
and
MEMBERS 1 ST FEDERAL CREDIT UNION,
Garnishee.
CIVIL DIVISION
No. 03-5853 CIVIL TERM
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TOPROTHONOTARY:
Please discontinue this action against the above garnishee, MEMBERS 1 ST
CREDIT UNION`and mark the docket accordingly.
Respectfully submitted,
CHROMULAKK &ASSOCIATES, L.LC
By. U "
CATHY ANN CHROMULAK, ESQU
MELISSA A. SHENKEL. ESQUIRE
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
Sworn to and subscribed
Before me this cV;? day
of J% 4ZV 2005.
NOWrial Seal
Mdmk L Wdola, Notary pd*
Cedi T*. WeNyrrp W County
kiyCa Wien Expires At 7, 2DOB
THIS IS AN ATTEM T TO
COLLECT A DEBT A D ANY
INFORMATION OBTAI ED WILL
BE USED FOR THAT P RPOSE.
CERTIFICATE OF SERVICE
I, Melissa A. Shenkel, Esquire, counsel for BENEFICIAL CONSUMER
COMPANY d/b/a BENEFICIAL CREDIT SERVICES, hereby certify that a trud and correct
copy of the foregoing Praecipe to Discontinue Against Garnishee Only was serged upon the
following by First Class Mail, postage prepaid on this 23rd day of March, 2005.
MEMBERS IST FEDERAL CREDIT
DELEASE MURPHY
5000 LOUISE DIRVE
P.O. BOX 40
MECHANICSBURG, PA 17055
GEORGE W. MANUAL a/k/a GEORG W.
MANUAL, JR.
THELMA MANUAL
465 N. PITTS STREET
CARLISE, PA 17013
A. Shenkel, Esq.
THIS IS AN ATTEM T TO
COLLECT A DEBT A D ANY
INFORMATION OBTAI ED WILL
BE USED FOR THAT P RPOSE.
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SHERIFF'S RETURN - GARNISHEE
%
CASE NO: 2003-05853 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
MANUAL GEORGE W E
And now ROBERT BITNER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn accorping
to law, at 0013:50 Hours, on the 17th day of February 2005,1,attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
MANUEL GEORGE W AKS GEORGE W. MANUEL JR ,I in the
hands, possession, or control of the within named Garnishee
MEMBERS 1ST FEDERAL CREDIT UNION
1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
LUANNE KYLE (ASST. MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION-REISSUE ar
the contents there of known to Her .
Sheriff's Costs
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
So R. Thomas Kline
Sheriff of Cumberland
00/00/0000
Sworn and subscribed to before me
Hy
this day of A.D.
+ Prothono any ?i? 'J
I
made
SHERIFF'S RETURN - GARNISHEE
41
CASE NO: 2003-05853 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
MANUAL GEORGE W ET AL
And now ROBERT BITNER Sheriff or Deputy Shei
Cumberland County of Pennsylvania, who being duly sworn accos
iff of
ng
to law, at 0013:50 Hours, on the 17th day of February , 2005, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
MANUEL THELMA J in the
hands, possession, or control of the within named Garnishee
MEMBERS 1ST FEDERAL CREDIT UNION
1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
LUANNE KYLE (ASST. MANAGER)
personally three copies of interogatories together with 3 true
1?id attested copies of the within WRIT OF EXECUTION-REISSUE and made
!e contents there of known to Her .
I eriff's Costs: 'I s' ?P
Docketing .00 Fr .]?
service 00
Affidavit .00 R. Thomas Kline
surcharge .00 Sheriff of Cumberland Co my
.00
00
00/00/0000
orn and subscribed to before me ?)
o\ day of Deputy Sheriff
e?Gx? A.D. Prothonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES,
CIVIL DIVISION
No. 03-5853 CIVIL TERM
Plaintiff,
vs.
GEORGE W. MANUAL a/k/a
GEORGE W. MANUAL JR.
and THELMA J. MANUAL,
Defendants,
and
MEMBERS 1 ST FEDERAL
CREDIT UNION,
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendants' Address:
465 NORTH PITT STREET
CARLISLE, PA 17013
Garnishee's Address:
1000 BRYN MAWR ROAD
CARLISLE, PA 17013
Date: May 31, 2007
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
FILED ON BEHALF OF:
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
41h Floor
Canonsburg, PA 15317
(724) 916-2400
fi
W
C7
cF t.° Fz
C_q
o a 0 r -? _ n
c e c o _?
r r,
ti S w 1
A - 1 .01 WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5853 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY
D/B/A BENEFICIAL CREDIT SERVICES, Plaintiff (s)
From GEORGE W. MANUAL A/K/A GEORGE W. MANUAL, JR., AND THELMA J.
MANUAL, 465 NORTH PITT STREET, 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 MEMBERS 1sT FEDERAL CREDIT UNION, 1000 BRYN MAWR ROAD, CARLISLE, PA
17013 - PURSUANT TO ALL MONIES DUE DEFENDANTS 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 $15.81 L.L.
Interest $403.69
Atty's Comm % Due Prothy $2.00
Atty Paid $119.00 Other Costs
Plaintiff Paid
Date: JUNE 5, 2007 72
s R. Long, Prothonotary
(Seal) By: '4?L4-. -0- _C7
Deputy
REQUESTING PARTY:
Name BETH ARNOLD HOWELL, 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. 203606
k.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES,
Plaintiff,
VS.
GEORGE W. MANUAL a/k/a GEORGE
W. MANUAL, JR. and THELMA J.
MANUAL,
AND
Defendants,
MEMEBERS 1 ST FEDERAL CREDIT
UNION,
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL
CIVIL DIVISION
No. 03-5853 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 CREDIT
SERVICES
COUNSEL OF RECORD:
60070 CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
v •
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL CREDIT
SERVICES,
Plaintiff,
Vs.
GEORGE W. MANUAL a/k/a GEORGE
W. MANUAL, JR. and THELMA J.
MANUAL,
DefendantS,
and
MEMEBERS 1 ST FEDERAL CREDIT UNION,
Garnishee.
CIVIL DIVISION
No. 03-5853 CIVIL TERM
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
Please discontinue this action against the above garnishee, MEMEBERS I ST FEDERAL
CREDIT UNION and mark the docket accordingly.
-viyiMONWEALTH OF PENNSYLVANIA
! Notarial Sergi
Heather L. Hatfield, Notary Public
Cecil Tm. Washington County
"Y Con trrrrssion Expires June 29, 2010
Pennsylvania Assoclation of Notaries
Sworn to and subscrib d
Before me this day
of A, - 2007.
m?-
Notary Pu lic
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
I (? - ' 11 -
??
BY•
CATHY ANN CHRO ULAIx, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
BETH ARNOLD HOWELL, ESQUIRE
CHRISTINE A. SAUNDERS
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
1
CERTIFICATE OF SERVICE
I, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a BENEFICIAL
CREDIT SERVICES, 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 June, 2007.
MEMEBERS 1 ST FEDERAL CREDIT UNION
CHIP MCBREEN
5000 LOUISE DRIVE
P.O. BOX 40
MECHANICSBURG, PA 17055
GEORGE W. MANUAL a/k/a
GEORGE W. MANUAL, JR.
THELMA J. MANUAL
465 NORTH PITT STREET
CARLISLE, PA 17013
1
Cathy Ann Chromul , 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.
r--3
Ar
Q
`~
1
a C
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 $
18.00
2.39
.50
1.00
20.85
30.00
40.00
9.00
121.74 ./ (-1 a " 1 01 47 , So Answers;
Advance Costs: 150.00
121.74
$ 178.26
Refunded to Atty on 06/19/07
R. Thomas Kline, 4eot
By kaZuUffi:?atA. Brewer
c
w
CPI
IV
ES *-b V L- 93.E 5001
JJ183HS 141 ?O 331330
t .? 590`??
,?? /9vG 93
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5853 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY
D/B/A BENEFICIAL CREDIT SERVICES, Plaintiff (s)
From GEORGE W. MANUAL A/K/A GEORGE W. MANUAL, JR. AND THELMA J.
MANUAL, 430 NORTH PITT STREET, 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 MEMBERS 1sT FEDERAL CREDIT UNION, 1000 BRYN MAWR ROAD, CARLISLE, PA
17013 - PURSUANT TO ALL MONIES DUE DEFENDANTS 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 $1,265.81 L.L. $.50
Interest TO DATE $282.46
Atty's Comm % Due Prothy $1.00
Atty Paid $99.50 Other Costs
Plaintiff Paid
Date: FEBRUARY 3, 2005
CURTIS R. LONG
Prothonot y
(Seal) B
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
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-05853 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
MANUAL GEORGE W ET AL
And now MICHAEL BARRICK
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:08 Hours, on the 20th day of June , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
MANUEL GEORGE W AKS GEORGE W. MANUEL JR
, in the
hands, possession, or control of the within named Garnishee
MEMBERS 1ST FEDERAL CREDIT UNION
1000 BRYN MAWR RD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BETH WAGNER (ASST MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscribed to
before me this
true
and made
So an c
.00
.00
.00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00
0 0 ?` G/a all 7
06/21/2007 e"??7 Z-x
day of By
Deputy Sheriff
A.D
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-05853 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
MANUAL GEORGE W ET AL
And now MICHAEL BARRICK
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:08 Hours, on the 20th day of June , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
MANUEL THELMA J , in the
hands, possession, or control of the within named Garnishee
MEMBERS FIRST FEDERAL CREDIT UNION
1000 BRYN MAWR RD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BETH WAGNER (ASST 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 answ rs
Docketing .00
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
0 0 (?,,?
. ? 4IA?Io9 '9'
06/21/2007
Sworn and Subscribed to --'-?
before me this day of By
Deputy Sheriff
A.D
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff s Costs: Advance Costs: 150.00
85.48
Docketing 18.00 $ 64.52
P d 168
oun age
Advertising
Law Library
Prothonotary 2.00
Mileage 4.80
Surcharge 30.00
Levy 20.00
Post Pone Sale
Garnishee 9.00
Refunded to Atty on 07/05/07
Postage
TOTAL $ 85.48 ? ??IG?o So Ans er .
R. Thomas Kline, Iheriiff
p, 0 --?- " 'J'/
By Claudia A. Brewbaker
0
'pro
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-5853 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 CREDIT SERVICES, Plaintiff (s)
From GEORGE W. MANUAL A/K/A GEORGE W. MANUAL, JR., AND THELMA J.
MANUAL, 465 NORTH PITT STREET, 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 MEMBERS 1sT FEDERAL CREDIT UNION, 1000 BRYN MAWR ROAD, CARLISLE, PA
17013 - PURSUANT TO ALL MONIES DUE DEFENDANTS 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 $15.81
Interest $403.69
Atty's Comm %
Atty Paid $119.00
Plaintiff Paid
Date: JUNE 5, 2007
(Seal)
REQUESTING PARTY:
Name BETH ARNOLD HOWELL, 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
-'F-'y
Supreme Court ID No. 203606