HomeMy WebLinkAbout08-2217IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY
Plaintiff
V.
RAFAEL R RIVERA and KIMBERLY A RIVERA
Defendant(s)
NO. D8 - ?- 13 onvi t Term
COMPLAINT IN CIVIL
ACTION
Filed on behalf of:
HOUSEHOLD FINANCE
CONSUMER DISCOUNT
COMPANY
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PF_PA_l I Cmplt Cvr Sht P&F File No. 07-20564
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY
Plaintiff
V.
RAFAEL R RIVERA and KIMBERLY A RIVERA
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 an 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.
NO. 6?,'2 )-1 7 c,,,; I
Usted ha sido demandado on cone. Si usted desea defenderse
de las demandas quo se presentan mas adelante on las
siguientes paginas, debe tomar action dentro de los proximos
veinte (20) dial despues de la notification de esta Demanda y
Aviso radicando personalmente o por medio de un abogado
unn comparecencia cscrita y radicando en la Corte por escrito
sus defensas de, y objections a, las demandas presentadas
aqui on contra suya. Se le advierte de que si usted fall de
tomar action como se describe anteriormente, el caso pude
proceder sin usted y un fallo por cualquier suma de dinero
reclamada en la demanda o cualquier reclamation o remedio
solicitado por el demandante puede ser dictado en contra suya
por la Corte sin mas aviso adicional. Usted puede perder
dinero o propiedad au otros derechos importantes para usted.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER
AT ONCE.IF YOU DO NOT HAVE A LAWYER GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS
OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR
ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
USTED DEBE LLEVAR ESTE DOCUMENTO A SU
ABOGADO INMEDIATAMENTE. SI USTED NO TIENE
UN ABOGADO, LLAME 0 VAYA A LA SIGUENTE
OFICINA. ESTA OFICINA PUEDE PROVEERLE
INFORMACION A CERCA DE COMO CONSEGUIR UN
ABOGADO
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE
UN ABOGADO, ES POSSIBLE QUE ESTA OFICINA LE
PUEDA PROVEER INFORMACION SOBRE AGENCIAS
QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0
BAJO COSO A PERSONAS QUE CALIFICAN.
CUMBERLAND COUNTY BAR
ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
PA-2 I Notice to Defend P&F File No. 07-20564
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY
Plaintiff
V.
RAFAEL R RIVERA and KIMBERLY A RIVERA
Defendant(s)
COMPLAINT IN CIVIL ACTION
NO. D ?. 217 C- tv' + ^
AND NOW, comes Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY, by and through its attorney, GREGG MORRIS, ESQUIRE and the law offices of
PATENAUDE & FELIX, A.P.C. and files the following Complaint in Civil Action, and in
support thereof aver as follows:
1. Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, is a
corporation with offices with an address for the purposes of this litigation C/O the law offices of
Patenaude and Felix, APC, 213 E. Main Street, Carnegie, PA.
2. Defendant(s) is RAFAEL R RIVERA, an adult individual, believed to currently
reside at 226 N BALTIMORE AVE APT 2 MOUNT HOLLY SPRINGS, PENNSYLVANIA
17065--120.
3. Defendant(s) is KIMBERLY A RIVERA, an adult individual, believed to
currently reside at 406 N PITT CARLISLE, PA 17013.
4. Heretofore, the Defendant(s) opened an account with Plaintiff being Account No.
PA-05A Civil Cmplt Crdt Line P&F File No. 07-20564
71330300132403. A copy of the Account Agreement is attached hereto as Plaintiffs Exhibit "A"
and is incorporated herein by reference..
5. The Defendant(s) made payments, but has refused to pay, and now refuses to pay
the balance due and owing on the aforesaid account and now the full amount of the account is
due and payable in the sum of $2,262.67 as of 08/26/2007, plus interest at 20.24 % and cost.
6. Plaintiff maintains accurate books of account recording all credits and debits for
this account.
7. Defendant(s) have/has received monthly billing statements from Plaintiff setting
forth the nature and amount of all debits and credits and the transactions between Plaintiff and
Defendant(s) give rise to an account stated, upon which Plaintiff has relied.
By failing to object or dispute the statements, Defendant(s) have/has assented to
and agreed to the correctness of the balance due on the credit card account so as to constitute and
account stated.
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in
the amountof $2,262.67 plus interest as attached hereto, with continuing interest thereon at the
legal rate from the date of Judgment plus costs.
Counts II
Breach of Contract
9. The averments of paragraphs 1 through 7 are incorporated herein by reference as
if the same were set forth herein at length.
10. Defendant(s) completed an Application for Credit and the Agreement is attached
hereto as Plaintiffs Exhibit "A" and is incorporated herein by reference.
11. Defendant(s) is in default for failing to make payments as due.
12. The terms of the Contract provided that Defendant(s) will pay Plaintiffs
PA-05A Civil Cmplt Crdt Line P&F File No. 07-20564
reasonable attorney's fees.
13. Plaintiff avers that counsel for Plaintiff is not a salaries employee of Plaintiff and
that such attorney's fees will amount to $800.00.
WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in
the amountof $2,262.67 plus interest as attached hereto, with continuing interest thereon at the
legal rate from the date of Judgment, reasonable attorney's fees in the amount of $800.00 plus
costs.
submitted:
& Felix, A.P.C.
Date:
GrVg L. Morris, Esquire
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA-05A Civil Cmplt Crdt Line P&F File No. 07-20564
NOV-14-200T 02:28PII FRWHOUSEHOLD SQUIRREL 184TZ887381 T-164 P.041/061 F-888
J.. ? ? I I
nuoNAL CRwrr LINE ACCOUNT Aoxm T1T (Pasep pf 4)
CREDITOR (called "We", "Us", "Out")
HOUSEHOLD FINANCE CONS"R DISCOUNT CONF'ANY
24 MJ MALL
CARLISLE PA 17013
BORROWERS (called "You", "Your") LOAN NC 71
RIVERA, RAFAEL R
RIVERA. KIMBERLY A
Me AMY OR
CARLISLE PA 17013
.01 AND OVER 1.042 % 18.600 % '
In this Agreement, "you". "your" and "Borrower" mean the customer(s) who gns this A got. "We", "us", "our" and
"Lender" refer to Hounahold, This Agreement covers the terms and conditii is of your ld Personal Credit Line
Account. We want you to undermnd how your Personal Credit Line Aim I n t tvww11k d this carefully, ask us any
cluesdong, and if you egm to be bound by this Agreement, sign below. li more than person sign& each grill bs
responsible for repaying all gums advanced under this Agreement.
Your personal Credit Line Account is a revolving line of credit extended to 1 -u and secu as described below. You can
obtain funds from your personal Credit Line Account (up to your credit lin t) directly vs or by using the special
checks we supply to you. You may pay your total unpaid balance at any time or :? instaltm
RBQLUM INSULANCS. You must obtain insurance for term of loan ooverioS 4ority for Ik rn as indicated by the word
"YBS" below, namiua us as Lou Payw.
Phyalcal damo`e insnrom on whisk listod under'Secutity" obaw. ' "Y" aPPaa u "Insured."
You may obtain any required Insurance from anyone you choom
OTIC& SI E TRI- FOLLOWING PAGES POR ADDITIONAL PROMS. INS AND RTANT INPORMAnON
REGARDING YOUR RIGHTS TO DIM= BILLING URRORS.
03-01-02 u!t Fa vp to Non-M PAOe l
+f /ail
NOV-14-2007 02;2SPIl FR*HDUSEIIOLD SQUIRREL
194T266TS61
1 ' PERSONAL CREDIT LINE ACCOUNT AGREE UM (Pal
Available Credit You may obtain funds directly from us or through your sl Biel checks
ccc must w :ten for at low 5100. Your available credit is your credit li: it (shown e
balance, including Finale Charges, of your Account. If you make loan pay, eats by dw
credit seven days after we receive your check to allow for check clearing. It yon -equest tuts
you to weed your available credit, we are not obligated to honor your regr st. If we do
available credit, you agree to pay us that excess amount, plus Finance Charges, nmedistell
T-164 P.042/061 F-666
of 4)
your lee's the total Available credit Each
or taspaid
we will adjust your available
s an amount that would saris
id you an amount over your
Promise to Par. You promise to pay Household: (a) amounts borrowed Soler this ant; (b) Pusanve CS ATSM
Ace metrauve arges (the bad check charge) and other charges provided in pia Agreeuts (c) credit iasuranoe dwgea,
if any; (d) collection costs permitted by applicable law, including ressonab : attorneys' T(if the aft" is not our
salaried employee) and court coati and (el amounts in excess of your creel limit that may kad you, plus Financa
Charges.
h Setts: You may repay your entire outstanding balance at any time wit
chocks to pay any amounts due under this Agreement. Because the Finance C
us regarding the exact payoff amount for the day you intend to make full pay,
your Account at o?see, you agree to pay at least the minimum payment abo%
indicated on the monthly statement. Payments will be applied as follows: First
Secmd, to any unpaid Admicistro6ve Charges provided in this Agreoment;'I
and Fourth, to the remaining outstanding unpaid balance of your Account. Any
To amounts borrowed on your Account will be applied to the amounts borrow
in the order in which the amounts were borrowed. Any part of your monthly p
be applied in the same macaw.
Your payment must be received by us at the address indicated on the montl t statement
she m on your aumthly statement. Payments received by us after 10410 a.m. antral Dayl
are received in California, after 10:00 a.m. PuMe Daylight Time, will be sec xd to your
day which is not a Saturday. Sunday or Back Holiday.
Minimum MonthlyPayment The Minimum Monthly Payment for any bill :g cycle will
or ua v c u7u? at me outsta mnS Account balance plus any Administrative Cl no and a+
to the sto@= SI; or (2) the Finance Charges due for the billing cycle plus any. dministrati
charges. In each instance, the Wnimum Monthly Payment will be adjusted xa include i
previous billing cycles.
Dart penalty may not use your special
srge is con ed each day, you will contact
eat. U you A n l om pay the entire balatrce on
on your stseat at the address
to any accgr id Furnace Charges;
?
ird, to any 6d
t insurance charges;
art of y yment to be applied
I under y redit lane Account
,mant to be inance Charges will
,or to the payment due date
t Time, or it your payments
;cunt as of the non business
the greater of (1) the grata
insurance charges, rounded
Varga and credit insurance
unpaid amounts due from
Finance Chaff The Finance Charge is the interest dwgcd on the balance of our ACCOUIL ' g each billing: cycle. The
Iftance go u calculated from the date that cads advance, chock or char ) is posted Accoutnunt The Irmanee
Charge is computed by multiplying the average daily balance in your Axvt t in each cycle times the monthly
periodic rata The average daily balance is determined by totaling all daily unpa t bal-pen billing cyela sad dividing
the wW by the number of days in that cycle. A daily unpaid balance is the at cunt owed day inducting any unpaid
Finance Charge, Administrative Charges, ad credit insurance charges for prior iUiag eycl
Variable Rates You agree that the monthly periodic rate used in determining our F will be a variable rate
which may Em-se from month to month. The monthly poriadic rate will be or -twelfth of avm of the ,Prune Rats plus
the number of percentage points as stated in the "Margin" box on page one. It monthly is rate win act exceed that
permitted by applicable law.
The Prime Rate applicable to any billing cycle will be the prime rate publish i is the "W
newspaper. on the fiat publication day of the month in which the billing cycle bi ins. If a rw
use the bighest of the raves is the range. When a change in the Prime Rate is pub shed, a dun
will take effect on the first day of the first complete billing cycle following the late of the;
will apply to new loans and charges, ad to the existing balam of your Aacoun The Initial
Account is shown an page sae.
If circumstances such as a change in the claw, any court ruling or discontinued I blication of
continue use of this variable rate index, we will change the index according w tl procedure
and Chooses is the Agreement."
Buso Journal," a budoess
is rates is public 4 we will
io the monthly periodic rate
elsange? The new rate
y periodic rate on your
index do not permit us to
out below in "Termination
An increase in the Prime Rate may increase the Annual Percentage Rate (come mding m monthly periodic rate) and
the minimum payment on your Account.
Bad Check Charge: If you pay by a check which is returned for any mason, you ill pay a charge of SZO.
Orel-as US PA M ice. NWPM I I PAeaaeea
NOV-14-2007 02:24PM FROM-HOUSEHOLD SQUIRREL
164TIlOT351 T-164 P-048/061 F-566
PERSONAL CREDIT UM ACCOUNT AOREBl1 SNT (Pe 3 4)
Other. Cho • You agree to pay any amounts actually incurred by Household or servie a in eonaeetion with the
PersoriTCnne Account for fees paid to public officials in connection wit recording, as or anti Wng a security
interest in the security. You agree that these fees may be charged to your Aooour balance.
Termination and Chan is the Agreement We con change the terms f this A t, including increasing
your Minimum Monthly aymen as increasing the marginal rate o Finance adding as annual fee
aadlor fns of tted by applicable loft, or change the Variable Bate ida. at an me. Prior written notice
will be provided you when required by applicable law unless you t resent to an=e before that time.
Changes nay apply to both new and outstanding belanow unless E ohibited pplicable low. However,
termination of your credit limit will occur only as provided in the 'Default 4 .d Caacdla of Agreement' paragraph.
Balances outstanding under this Agreement when the credit limit is reduced or t minted i ontinuctoaccruciatemat
the variable contrsctrate until paid in full.
Default ad Cancellation of Agreement
We ve t to require you pay your entire balance plus all other sear id but unpa immediately and to
cancel your credit privilege under this Agreement because of.
(a) failumto make any payments in full when due under this Agreement,
(b) frequentoverdrawing of your line of credit;
(o) failure to Supply us with any information requested;
(d supplying us with misleading, false, incomplete or incorreotinformad. r,
(e breaking any of the practises, terms or conditions that are contained in his Agresm ;
(f) thafiling of a bankruptcy petition by or against you; or
(g) the death of any borrower who signs this Agreement.
After default. you will pay our court costs, reasonable attorney fees (if atom is not our tried employ"), and other
collection costa related to the default, if not prohibited by applicable law. Your y be award sonable attoraeyes fees if
you prevail in sn action against us.
YOUR BILLING RIGHTS
KEEP THIS NOTICE FOR FUTURE 'SE
This notice contains important information about your rights and Household's r ponsibilid er the Fair Credit Billing
Act.
Notify Household Ia Case of Errors or Questions About Your Bill
If you think your bill is wrong, or if you need more information about a traru ction on ill, write Household on a
separate sheet at the address listed on your bill after the words: "Send your billi g error a (Household's name and
Household must hear from ou no later
address)
" Write to Household as soar as
ossible in 60 days after Household
.
p
.
salt you the first bill on which the error or problem appeared. You can telephom Household, doing so wiH not preserve
your rights.
In your letter, Siva Household the following information:
• Your name and Account number.
a The dollar amount of the suspected error.
• Describe the error and explain, if you can, why you believe there is n error. If need more information,
descrt'bethe item you arc not sure about.
Your Rights and Household's ResponsibilhiesAfter Household Receives our Writt otice
Household must acknowledge your letter within 30 days, unless Household her c erected the r by then. Within 90 days.
HoueeDold must either correct the error or explain why Household believes the bi was car
After Household reoeivea your letter, Household cannot try to collect any arnoun rou questia L. report you as delinquent.
Household can continue to bill you for the amount you question, including fins x charges, Household an apply any
unpaid amount against your credit limit. You do not have to pay any questioned mount whi d is investipting.
but you are still obligated to pay the parts of your Will that are not in question.
If Household finds that Household made a mistake on your bill, you will not ha't to pay any I nee charges related to any
questioned amount. If Household did not make a mistake, you may have to pay f fiance chi you will have to mabe
up any missed payments on the questioned amount. In either case, Household wi and you a ent of the amount you
owe and the date that it is due.
0"1-62 us FA VR RL Nown I I PAOafM
1011.14-200T OY:Z4PM FROM-HOUSEHOLD SQUIRREL
184TY88T351 T-164 P-044/081 F-686
1 I
PERSONAL CREDIT LIVE ACCOUNT AGREE [ENT
if you fail to pay the amount that Household thinks you owe, Household nay report
Household's explanation does cot satisfy you and you write to Household wi un ten days
retuse to pay, Household must tell anyone Household reports you to that ?ou have a
Household must tell you the name of anyone Household reported you to. He isehold mu
you to that the matter has been settled between us when it finally is.
If Household doesn't follow these rules. Household can't collect the first SA c the questin
correct.
Before signing this Agreeaeent, you have read and received this Agra
disdlocurea conuined in it.
yon; the oustomcr(s) signing below, aSM to observe the terms and co
This loan is govmed by the Pennsylvania Consumer Discount Comps
(SEAL.)
lure Do%= in Z?'Zu
Witnesx fav ?• sd?f (SEAL)
er ? j
Date; Ja_._6
mcnt and
iitions of
y Loan A
AW
of 4)
as delinquent. However, if
ng Household that you still
Lion about ywx bill. And,
anyone Housebold reports
even it your bail was
Federal Truth itt-Lending
Agrocamt,
d applicable Federal law.
(sue.)
(OW
W-01-M LAN N1 VR X NW-W I I PAesesel
•NOV-14-200T 02:26PM FR*HOUSEHOLD SQUIRREL 18472887851
LOAN CLOSING STATEmn r
REVOLVING LOAN VOUCH R
CWWrrOR
HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY
24 W MALL
CARLISLE PA 17013
BOBROWEBS
RIVERA, RAFAEL R LOAr NO. 71
RIVERA, KIMBERLY A
108 AMY OR
CARLISLE PA 17013
Borrowers W" TO and direct the disbursements and Advance indicated be n?. If any
varies from the actual amount paid, Borrowers agree to the disbursement 3f the acs
change to dw Advance shown below. Borrowera av= that this Advance made un
Agreement (acewint number shown above.)
TO: RAFEAL AND KIM RIVERA ................................
TOTAL ADVANCE(S) .......................... ............... .......
C.
N?
L
0AXE
02-01-N 1L Vrider 15T Wiam
BORROWED
q AIA-
.Ar #,,A.
T-164 P.060/061 F-586
744234
amount shorn below
inn
me Revolving
•••••..i 2500.00
.••..: 2500.00
PA13MI
The undersigned, Gregg L. Morris, hereby states that he is the attorney for Plaintiff in
this action and verifies that the statements made in the foregoing pleading are true and correct to
the best of his knowledge, information and belief. Counsel has signed the verification at the
request of Plaintiff as a matter of time and convenience. Plaintiff has represented to counsel that
there is a debt due and owing from Defendant to Plaintiff in the amount as set forth within the
foregoing pleading. Plaintiff has provided counsel with all relevant information in order to allow
counsel to sign this verification. Plaintiff agrees to provide a verification signed by Plaintiff
upon request by Defendant. The statements are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unworn falsification to authorities.
Date:
Pro& L. Morris, Esquire
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA-01 Arty Verification P&F File No. 07-20564
? N
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((MM
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cc
VJ C-n
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0
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-02217 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS ?-
VS
RIVERA RAFAEL R ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
RIVERA RAFAEL R but was
unable to locate Him in his bailiwick
COMPLAINT & NOTICE ,
He therefore returns the
the within named DEFENDANT
NOT FOUND , as to
RIVERA RAFAEL R
226 N BALTIMORE AVENUE APT 2
MT HOLLY SPRINGS, PA 17065
GIVEN ADDRESS IS NOW A PARKING LOT.
Sheriff's Costs:
Docketing 18.00
Service 7.00
Not Found 5.00
Surcharge 10.00
00
y4 40.00
So answers:-
R. Thomas Kline
Sheriff of Cumberland County
PATENAUDE & FELIX
04/10/2008
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-02217 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
RIVERA RAFAEL R ET AL
DAVID MCKINNEY Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
RIVERA KIMBERLY A the ..
DEFENDANT at 1550:00 HOURS, on the 8th day of April 2008
at 406 N PITT STREET
CARLISLE, PA 17013 by handing to
VIRGINIA BARRICK, MOTHER
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: So Answers:
Docketing 6.00
Service 5.00
Affidavit 00
Surcharge 10.00 R. Thomas Kline
.00
4Jt??0? 21.00 04/10/2008
PATENAUDE & FELIX
Sworn and Subscibed to By:
12 ?
,
w /-/
before me this day D puty -
Sher' i f
of A.D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY
Plaintiff
V.
RAFAEL R RIVERA and KIMBERLY A RIVERA
Defendant(s)
NO. 08-2217
PRAECIPE TO
DISCONTINUE WITH
PREJUDICE
Filed on behalf of:
HOUSEHOLD FINANCE
CONSUMER DISCOUNT
COMPANY
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA-169 Prcp Disc with Ndc
P&F File No. 07-20564
INTHV COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
` PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY
NO. 08-2217
Plaintiff
V.
RAFAEL R RIVERA and KIMBERLY A RIVERA
Defendant(s)
PRAECIPE TO DISCONTINUE WITH PREJUDICE
TO: Prothonotary
Please discontinue the matter captioned above with prejudice. Thank you.
submitted:
Paten4de & Felix, A.P.C.
Date:
g Morris, Esc
r E. t`t et
Carn egie, PA 15106
(412) 429-7675
Sworn to and subscribed before me this
day of , 200K
Jli;?
Notary Publ
61
COMMC'i EA fN ?. fWNrie L- PfIA
NO" 8"
Carolyn J. SWAwt, Notary Publics
Came* Bore, Al 0'" Caurriy
My Commiseiors Esrpires Aug. 14, 2011
Member, Pennsylvania Association of Notaries
PA-169 Prcp Disc with Prjdc P&F File No. 07-20564
I, GREGG MORRIS, attorney for Plaintiff, HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY, hereby certify that a true and correct copy of foregoing document
was served this date by ordinary mail upon the following:
Date:
Kimberly A Rivera
406 N Pitt
Carlisle PA 17013 ,
gate de & Felix, A.P.C.
13 . Main Street
ie, PA 15106
(412) 429-7675
PA-169 Prep Disc with Pddc P&F File No. 07-20564
C.=o -11
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