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HomeMy WebLinkAbout03-6557IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPAiNY, Plaintiff, VS. SHERRY Y. RITCHEY, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION _ .rx7 TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Defendant's Address: 4707 North Clearview [)rive Camp Hill, PA 17011 THI$1S 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 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff, Vs. CIVIL DIVISION No. SHERRY Y. RITCHEY 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 fights 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, VS. SHERRY Y. RITCHEY, Plaintiff, Defendant. CIVIL DIVISION No. COMPLAINT AND NOW COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, by its Attorneys, Mollica & Chromulak, with its Civil Action Complaint, the following of which is a statement thereof: 1. HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY is a Corporation, duly authorized to conduct business in the Commonwealth of Pennsylvania, with its principal office situated at 2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred to as "Plaintiff". 2. SHERRY Y. RITCHEY is an adult individual residing at 4707 North Clearview Drive, Camp Hill, PA 17011. 3. On or about October 21, 2002, Defendant entered into a Loan Agreement with the Plaintiff, a copy of which is attached hereto as "Exhibit A" and incorporated herein. Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Pursuant to the Loan Agreement with Defendant, Plaintiff advanced funds to the 5. Defendant is in default under the terms and conditions of the aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about April 24, 2003. 6. Pursuant to the terms of the Loan Agreement, Plaintiff has the ri~t to require payment of the entire amount owed upon default. The total amount due, including principal and interest, and owing by the Defendant is in the sum of Six Thousand, Nine Hundred Forty-Eight and 40/100 ($6,948.40) Dollars as of November 11, 2003. 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 costs of collection and reasonable attorney's fees. WHEREFORE, Plaintiff claims damages in the sum of Six Thousand, Nine Hundred Forty-Eight and 40/100 ($6,948.40) Dollars, with interest thereon at the rate of 25.697% from November 11, 2003, plus court costs and attorney's fees. Respectfully submitted, Mollica & Chromulak 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. 0 I, A.,~ela D,,vi~, Sr. Clerk for HOUSEHOLD ~INANCE CONSUMER DISCOUNT COh~ANY, A HOUSEHOLD INTEE/~ATIONAL COMPANY ~ ~o~ed~ ink--don and bell~ ~d ~ I ~ ~ m ~ suoh Comp~nt I ~d ~at f~c s~m~ h~in ~ ~ subj~ot [o &~ ~al~es of 18 P~ Angels Davi~ Dlted: 12-19-2003 SHERIFF'S RETURN - CASE NO: 2003-06557 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS RITCHEY SHERRY Y REGULAR BRIAN BARRICK Cumberland County,Pennsylvania, says, the within COMPLAINT & NOTICE RITCHEY SHERRY Y DEFENDANT , at 1627:00 HOURS, at 4707 NORTH CLEARVIEW DR. CAMP HILL, PA 17011 RUSSELL RITCHEY, SON a Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 2nd day of January , 2004 by handing to true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.97 Affidavit .00 Surcharge 10.00 .00 36.97 Sworn and Subscribed to before me this ~'~ day of So Answers: R. Thomas Kline 01/0 2004 MOLLICA & CHRO~ By: De[Duty Sheriff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. SHERRY Y. RITCHEY, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, 1L 60070 Defendant's Address: 4707 NORTH CLEARVIEW DR1VE CAMP HILL, PA 17011 CIVIL DIVISION No. 03-6557 CIVIL TERM TYPE OF PLEADING: Praecipe for Default Judgment TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQUIRE PA ID NO. 42067 MAUREEN A. DOWD, ESQUIRE PA ID NO. 90549 SCOTT E. CRAWFORD, ESQUIRE PA ID NO. 89570 CHROMULAK & ASSOCIATES, L.L.C. Dated: February 3, 2004 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 THISI$ AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. TO: PROTHONOTARY Please enter judgment by default against the within-named defendant, SHERRY Y. RITCHEY, for failure to file an Answer as follows: Amount claimed in Complaint: $6,948.40 Interest from 11/12/03 through 2/03/04: 407.62 Costs of Collection through 2/03/04: 501.47 TOTAL $7,857.49 With interest accruing on the total balance of $7~857.49 at the rote of 6% per annum, together with additional costs of suit. CATHY ANN CHROMULAK, ESQUIRE MAUREEN A. DOWD, ESQUIRE SCOTT E. CRAWFORD, ESQUIRE Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATION OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) ) COUNTY OF ALLEGHENY ) SS: Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared SCOTT E. CRAWFORD, ESQUIRE, attorney for and authorized representative o f plaintiff w ho, being duly s worn according t o 1 aw, deposes a nd says t hat the defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was marled to defendant on JANUARY 23, 2004 by certificate of mailing in accordance with Pa.R.C.P, 237. l, as evidenced by the attached copy. CATHY ANN CHROMULAK, ESQUIRE MAUREEN A. DOWD, ESQUIRE SCOTT E. CRAWFORD, ESQUIRE Sworn to and subscribed before me This o.O'~l _ day oft~,~ , 2004. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff, Vs. SHERRY Y. RITCHEY Defendant(s) CIVIL DIVISION No. 03-6557 CIVIL TERM TO: SHERRY Y. RITCHEY 4707 NORTH CLEARVIEW DRIVE CAMP HILL, PA 17011 DATE OF NOTICE: JANUARY 23, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717~249-3166 or 800-990-9108 By: CATHY ANN CHROMULAK, ESQ. SCOTT E. CRAWFORD, ESQ. Attomeys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 THISISAN ATTEMPT TO COLLECTA DEBTANDANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. SHERRY Y. RITCHEY, and CITIZENS BANK, Defendant, Garnishee. PlaintifFs Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 4707 NORTH CLEARVIEW DRIVE CAMP HILL, PA 17011 Gamishee's Address: 665 NORTH EAST STREET CARLISLE, PA 17013 Date: March 11, 2004 CIVIL DIVISION No. 03-6557 CIVIL TERM TYPE OF PLEADING: PRAECI]?E FOR A WRIT OF EXECUTION FILED ON BEHALF OF: HOUSEHOLD FENANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA 1D NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 CHROMULAK & ASSOCIATES, EEC. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916~2400 THIS IS AN A"I'TEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, VS. SHERRY Y. RITCHEY, and CITIZENS BANK, Plaintiff, Defendant, Garnishee. CIVIL DIVISION No. 03-6557 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO: The Prothonotary Please issue a Writ of Execution in the above matter, 1. directed to the Sheriffof CUMBERLAND County; 2. against SHERRY Y. RITCHEY, defendant, and 3. against CITIZENS BANK, garnishee, 4. and index this writ a. against SHERRY Y. RITCHEY, defendant, and b. against CITIZENS BANK, garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual and ioint, personal and business. Amount of Judgment Additional Interest to Date (Costs to be added) $7,857.49 $ 47.14 $ 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. $7,9O4.63 SCOTT E. CRAWFORD, ESQ. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-6557 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONS. DISC. CO. Plaintiff (s) From SHERRY Y. RITCHEY, 4707 N. CLEARVIEW DR., CAMP HILL PA 17011. (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 CITIZENS BANK, 665 N. EAST ST.,, CARLISLE PA 17013 GARNISHEE(S) as follows: ANY PROPERTY OF DEFT. IN THE NAME OF GARNISHEE PURSUANT TO ALL MONIES DUE DEFT. IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS AND SERVE IN TERROGATORIES. 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 thereofi (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 am directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $7,,857.49 Interest TO DATE = $47.14 Atty's Corem % Atty Paid $118.97 Plaintiff Paid Date: MARCH 15, 2004 (Seal) REQUESTING PARTY: Name SCOTT E. CRAWFORD, ESQ. L.L.$.50 Due Prothy $1.00 Other Costs TAX DUE ~ $.50 Address: 375 SOUTHPOINTE BLVD., 4m FLOOR CANONSBURG PA 15317 Attorney for: PLAINTIFF Telephone: (724) 916-2400 Supreme Court ID No. 89570 CURTIS R. LONG Prothon~ary SHERIFF'S RETURN - CASE NO: 2003-06557 P COMMONWEALTH OF PENNSLYVA_NIA COUNTY OF CUMBERLAND GARNISHEE HOUSEHOLD FINANCE CONSUMER VS RITCHEY SHERRY Y And now VALARIE WEARY Cumberland County of Pennsylvania, to law, at 0009:30 Hours, on the 19th day of March as herein commanded all goods, chattels, moneys of the within named DEFENDANT , RITCHEY SHERRY Y hands, ,Sheriff or Deputy Sheriff of who being duly sworn according , 2004, attached rights, debts, credits, and possession, or control of the within named Garnishee , in the CITIZENS BANK 665 N. EAST ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to CONNIE DZEZINSKI (BRANCH 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: Docketing .00 Service .00 Affidavit .00 Surcharge 000 o00 .00 R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo Sworn and subscribed to before me this ~3~t day ~o~7 A.D. Pr~t{qonot ary ' By IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. CIVIL DIVISION No. 03-6557 CIVIL TERM SHERRY Y. RITCHEY, and CITIZENS BANK, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant, Garnishee. TYPE OF PLEADING: Praecipe to Settle and Discontim~e Against Garnishee ONLY 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 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 CHROMU]LAK & 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 COMPANY, Plaintiff, VS. SHERRY Y. RITCHEY, and Defendant, CITIZENS BANK, Garnishee. CIVIL DIVISION No. 03-6557 CIVIL TERM PRAECIPE TO SETTLE AND DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please settle and discontinue this action against the above garnishee, CITIZENS BANK and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. Sworn to and subscribed Before me this o~/-/a6 day o~o~. ~q , 2004. CATHY ANN CE[ROMULAK, ESQUIRE SCOTT E. CRAWFORD, ESQUIRE Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15;317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL lie USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Scott E. Crawford, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a tree and correcl 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 23rd day of March, 2004. CITIZENS BANK 525 WILLIAM PENN PLACE, SUITE 153-2510 PITTSBURGH, PA 15219 SHERRY Y. RITCHEY 4707 NORTH CLEARVIEW DRIVE CAMP HILL, PA 17011 Sqott E. Crawford, Esq. Dated: March 23, 2004 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 F1NANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. SHERRY Y. RITCHEY, and M & T BANK, Defendant, Garnishee. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 4707 NORTH CLEARVIEW DRIVE CAMP HiLL, PA 17011 Garnishee's Address: 2 W. HIGH STREET CARLISLE, PA 17013 Date: JUNE 22, 2004 CIVIL DIVISION No. 03-6557 CWIL TERM TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. 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 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 COMPANY, VS. SHERRY Y. RITCHEY, and M & T BANK, Plaintiff, Defendant, Garnishee. CIVIL DIVISION No. 03-6557 CWIL 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 SHERRY Y. RITCHEY, defendant, and 3. against M & T BANK, garnishee, 4. and index this writ a. against SHERRY Y. RITCHEY, defendant, and b. against M & T BANK, garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual/md ioint, personal and business: Amount of Judgment Additional Interest to Date (Costs to be added) $7,857.49 $ 182.09 $ 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. $8,039.58 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-6557 Civil COUNTY OF CUMBERLAND) CIVIL ACTION- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From SHERRY Y. RITCHEY, 4707 NORTH CLEARVIEW DRIVE, CAMP HILL, PA 17011 (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 M & T BANK, 2 W. HIGH STREET, CARLISLE, PA 17013, ALL MONIES DUE DEFENDANT 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 fi.om 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 $7,857.49 Interest TO DATE - $182.09 Atty's Corem % Atty Paid $131.47 Plaintiff Paid Date: JUNE 24, 2004 (Sea~ CURTIS R. LONG Pr o thon~)ey Deputy L.L. $.50 Due Prothy $1.00 Other Costs REQUESTING PARTY: Name SCOTT E. CRAWFORD, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TM FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 89570 SHERIFF,S RETURN - CASE NO: 2003-06557 p COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLA2qD GARNISHEE HOUSEHOLD FINANCE CONSL~ER VS RITCHEY SHERRY y And now RON KERR ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly SWorn according to law, at 00___14:15 Hours, on the ~St~hh day of June__ , 2_00~, attached as herein Commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT RITCHEY SHERRY y hands, possession, or control of the within named Garnishee M & T BANK 2 WEST HIGH ST , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to TAMy BRICKNER (CUSTOMER SERVICE) personally three copies of interogatories together with and attested copies of the within WRIT OF EXECUTION the contents there of known to He___~r. Sheriff,s Costs: Docketing Service Affidavit Surcharge true and made oo/oo/oooo Sworn and subscribed to before me this _7~ day of ~/~ By ~.~,__ /~~ -~T %' ~.D. -- Deputy She~ff Ero~dnota~y , , ~ So ans .o0 .00 ~ .00 R. Thomas KIi~e-- .00 Sheriff of Cumbe-~-~and Co~nty- __ .00 .00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FiNANCE CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL DIVISION No. 03-6557 CIViL TERM VS. SHERRY y. RITCHEY, and Defendant, M & T BANK Garnishee. TO: M & TBANK 2 W. HIGH STREET CARLISLE, PA 17013 You are required to file Answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. INTERROGATORIES TO GARNISHEE FIRST: At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him/her on any negotiable or other written instrument, or did he/she claim that you owed him/her any money or that you were liable to him/her for any reason: RESPONSE: M & T BANK HAS NO OPEN ACCOUNTS SECOND: If your response to the previous interrogatory was anything other than an unqualified negative, set forth the amount of the claim, and identify the written instrument, if any, that forms the basis of the claim. RESPONSE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIRD: At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the Defendant? The scope of this interrogatory encompasses, but is not restricted to, the contents of any bank account(s). RESPONSE____2 FOURTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPQNSE: FIFTH: At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the Defendant (or in which Defendant) held or claimed any interest. RESPONSE: SIXTH: If your response to the previous inte~ogatoW was ~ing other th~ ~ ~qualified negative, identify the prope~y, ~d in the case of monet~ ~sets, state ~e ~o~t. ~SPONSE: SEVENTH: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which the Defendant had any interest? RESPONSE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EIGHTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: NINTH: At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefore? HA,S N,.. RESPONSE: TENTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount, and state the date of the transfer and the name and address of the transferee(s). RESPONSE: ELEVENTH: At any time after you were served, did you pay, transfer or deliver any money or property of the Defendant or to any person or place pursuant to their direction or otherwise discharge any claim of the Defendant against you? RESPONSE: THI$1S AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. TWELFTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, in the case of monetary assets, state the amount, and state the date of transfer and the name and address of the transferee(s). RESPONSE: Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. Cathy Ann Chronmlak, Esq. Maureen A. Dowd, Esq. Scott E. Crawford, Esq. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 THISI$ AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. SHERRY y. RITCHEY, and M & T BANK, Defendant, Garnishee. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION No. 03-655;7 CIVIL TERM TYPE OF PLEADING: Praecipe to Settle and Discontinue Against Garnishee ONLY 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 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 HEATHER C. TROXEL, ESQ. PA ID NO. 91848 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO ~OLLECT A DEBT AND ANY INIFORMATION OBTAINED WILL BE.: USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. SHERRY Y. RITCHEY, and Defendant, M & T BANK, Garnishee. CIVIL DIVISION No. 03-6557 CIVIL TERM PRAECIPE TO SETTLE AND DISCONTINUE AGAINST GARNISHEE ONLV TO PROTHONOTARY: Please settle and discontinue this action against the above garnishee, M & T BANK and mark the docket accordingly. Respectfully submi[tted, CHROMULAK & ASSOCIATES, L.L.C. CATHY ANN CHROMULAK, ESQUIRE SCOTT E. CRAWFORD, ESQUIRE HEATHER C. TROXEL, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscribed Before me this o¢,~t) day of ~--~z_y ,2004. Notary Pub],c~ ~r~ L y ~mlle~ E~r~ M~ 13, ~ THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY II~IFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Scott E. Crawford, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a tree 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 23rd day of July, 2004. M & T BANK P.O. BOX 844 BUFFALO, NY 14240 SHERRY Y. RITCHEY 4707 NORTH CLEARVIEW DRIVE CAMP HILL, PA 17011 Scott E. Crawford, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 18.00 Poundage 1.64 Advertising Law Library .50 Prothonotary 1.00 Mileage 3.45 Surcharge 30.00 Levy 20.00 Certified Mail Post Pone Saie Garnishee 9.00 TOTAL $ 83.59 Advance Costs: 150.00 Sheriff's Costs: 83.59 $ 66.41 Refunded to Atty on 08/09/04 Sworn and Subscribed to before me This 17~a' day of 2004A.0. (~- tQ ~-~, · Prothonotary So Answers; uNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: sHERRY Y. RITCHEY, DENNIS R. RITCHEY Debtors SHERRY Y. RITCHEY Movant 1N BANKRUPTCY BK. NO. 1;04-04580 CHAPTER 7 PROCEEDING L~!EN AVOIDANCE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, pENNSYLVANIA WRIT OF EXECUT][ON NO. 03-6557 HOUSEHOLD FINANCE cONSUMER : DISCOUNT : Respondent ORDER OF COURT~BY-DEFAULT AND NOW, this ~day of ' ,~~, 20(14 in consideration of the within Motion for Entry of Judgment by De[~the Debtor/Movant, the Court finds the Respondent has failed to file an Answer or otherwise plead to the Motion for an Order Avoiding ~ rved u on the Respondent on August 18, 2004; . . · .- Au ust l o, 2004 an. d~dul.y, se. ~. /Movant, Sherry Y. Ritch?., ~nd .lUdlClal L?n ~ed on , ~ :--a~-~ent by demult m favor of.Debtor -- .~ ,~nef renuested tn the therefore, the court.orafi~ J~.~['~ld F~nance Consumer D~scount, as to against the Responoem, nu~o ion Mot · . . ~ ~ ..... a *hat the iudgment lien hel.d by~ the ,~ ,~ m:~r. ra¥ ORDERED, adjudgea aha u~t~,~..-p ..~ ~_~+,, a,,A of no further force x ~ to · ~,~,'~y '~-,-. ~ ~^-,ont i~ hereby declared vo~Ct m Respondent agai?! t!xe ge~?~"~o,i,~n 547i[~(43(a) and 522(h) as a prezere-~. and effect as it vtotates l ~ u.o.,-- BY THE COURT '