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Home My WebLink About08-0429Q? n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff, Vs. VERNON E. SMITH Defendant(s) CIVIL DIVISION No. N - M aq Civil Term 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 ?f claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose j 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 TELEPHONES THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ?i 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 !t r M t. y IN-THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No D 8 - y as '?J - -Vs. VERNON E. SMITH, k- {.F Plaintiff .s Addres§- 2700 Sanders Road Prospect Heights, T'L 60070 Plaintiff, Defendant. Defendant's Address: 4611 FLORENCE"AVENUE APT. A MECHANICSBU? G, PA 17055 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OOSTAINED WILL BE USED FOR TIRAT PURPOSE. TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 CHRISTINE A. SAUNDERS, ESQ. PA ID NO. 203373 TERESA K. GABRIEL, ESQ. PA ID NO. 205696 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 4'' Floor Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. VERNON E. SMITH, CIVIL DIVISION No. b ?- v.d g ?'-? 7Jw-- Defendant. e AND NOW COMPLAINT COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, by its Attorneys, Chromulak & Associates, LLC, with its Civil Action Complaint,"'the following of which is a statement thereof: 1. HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY is a Corporation, duly luthorized 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. VERNON E. SMITH is an adult individual residing at 4611 FLORENCE AVENUE, APT. ?, MECHANICSBURG, PA 17055. 3.' On for about SEPTEMBER 23, 2002, Defendant entered into a written Loan Agreement with the Plaintiff, as evidenced by the Affidavit of Lost Note, a copy of which is attached hereto as,,, Exhibit A" and incorporated herein. 4.` Pursuant to the Loan Agreement with Defendant, Plaintiff advanced funds to the Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT ARID ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Vx Defendant is in default under the terms and conditions of the aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about APRIL 23, 2007. 6. Pursuant to the terms of the Loan Agreement, Plaintiff has the right to require t? payment of the entire amount owed upon default. The total amount due, including principal and interest, and owing by the Defendant is in the sum of THREE THOUSAND FOUR HUNDRED SEVENTEEN AND 31/100 ($3,417.31) DOLLARS as of NOVEMBER 28, 2007. '7. Numerous demands have been made upon Defendant by Plaintiff, but Defendant has failed or refused to pay. 8. Pursuant to the Loan Agreement, Plaintiff is entitled to recover the entire indebtedness, including without limitation, principal, accrued interest, costs of collection and reasonable attornek s fees. WHERE?, RE, Plaintiff claims damages in the sum of THREE THOUSAND FOUR x HUNDRED SEVENTEEN AND 31/100 ($3,417.31) DOLLARS, with interest thereon at the rate of '1399% from NOVEMBER 29, 2007, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC c By: L? CATHY ANN CHRO LAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 CHRISTINE A. SAUNDERS, ESQ. :. PA ID NO. 203373 TERESA K. GABRIEL, ESQ. PA ID NO. 205696 THIS IS AN ATTEMPT *0 COLLECT A DEBT AND ANY INFORMATION OBTAINEW'WILL BE USED FOR THAT PURPOSE. Attorneys for Plaintiff 375 Southpointe Boulevard 4t' Floor Canonsburg, PA 15317 HCS-HFC Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. Defendant(s) VFRNON SMTTH Case No.: AFFIDAVIT OF LOST/DESTROYED INSTRUMENT Dinita Brazell, being sworn deposes and says: EXHIBIT `A 1. That he/she is the Legal Specialist at HCS-HFC and makes this Affidavit on their behalf. 2. That this Affidavit is made on information and belief of the affiant after thorough review of all records of HCS-HFC pertinent to the Defendant's account. 3. That the original contract in this matter has been destroyed or lost. 4. That if originals or duplicates are discovered, they will be submitted to the Court for cancellation. PENNSYLVANIA ,,Vrn `,m "'t Subscribed and swo o before me on this day of tLem)>e, , 2007. Notary Public YVETTE M. STEPHEN Notary Public Commonwealth of Virginia 279672 My Commission Expires Oct 31, 2008 VERIFICATION Linda Szudora, Recover Specialist for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Deposes and says subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities, that the facts set forth in the forgoing Complaint are true and correct to the best of her knowledge, information and belief. ell r Linda Szudora U u ? co ra ;.r?t 0 iI SHERIFF'S RETURN - REGULAR CASE NO: 2008-00429 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER DIS i VS SMITH VERNON E MARK CONKLIN , Sheriff or Deputy heriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon --l .,,-,r,,T, - n the DEFENDANT , at 1505:00 HOURS, on the 23rd day of January 2008 at 4611 FLORENCE AVENUE APT A MECHANICSBURG, PA 17055 by handing to LOUISE MARTLEW, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to tl?e contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.52 Affidavit .00 Surcharge 10.00 00 3 9. 5 2 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 01/24/2008 CHROMULAK & ASSOCIATES BY z /I Z D(E!Dutf4--Sher1t t A. D. .1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Household Finance Consumer Discount Company, CIVIL DIVISION: Plaintiff, No. 08-429 Civil Term vs. Vernon E. Smith Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 TYPE OF PLEADING: Praecipe to Discontinue Without Prejudice TYPE OF CASE: Civil Action FILED ON BEHALF OF: Household Finance Consumer Discount Company COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 TERESA K. GABRIEL, ESQ. PA ID NO.205696 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Household Finance Consumer Discount CIVIL DIVISION: Company, vs. Plaintiff, No. 08-429 Civil Term . Vernon E. Smith Defendant. PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Please discontinue without prejudice the above-captioned action and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By:_??r?l?/ 1.P?1_? CATHY ANN CHROMULAK, ESQ. BETH ARNOLD HOWELL, ESQ. TERESA K. GABRIEL, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscri bed Before me this L day of ,2008- THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY Notary Pub is INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COMMONWEALTH OF PENNSYLVANIw Notarial Seal Heather L Hatfield, Notary Public Cecil Twp., Washington County My Cornrnission E)pires June 29, 2010 CERTIFICATE OF SERVICE I, counsel for Household Finance Consumer Discount Company, hereby certify that a true and correct copy of the foregoing Praecipe to Discontinue without Prejudice was served upon the following by First Class Mail, postage prepaid on this 6th day of March, 2008. Vernon E. Smith 4611 Florence Ave., Apt.A Mechanicsburg, Pa 17055 &A-t& jAnn Chromulak, Esq. Beth Arnold Howell, Esq. Teresa K. Gabriel, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. n N c ? o 4b C? ?? cn t