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HomeMy WebLinkAbout08-4154IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A. Plaintiff, CIVIL DIVISION Vs. Raphael Acevedo No. .1)g; w 1?1?5 &j 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 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, Successor in Interest to HSBC Bank USA, N.A., CIVIL DIVISION No. op- y1s)( w( 7--e ? Plaintiff, VS. TYPE OF PLEADING: Raphael Acevedo, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 1162 Heron Court Mechanicsburg PA 17050 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A. COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 ,NTH ARNOLD HOWELL, ESQ. PA ID NO. 203606 TERESA K. FUCHS, ESQ. PA ID NO. 205696 JENNIFER M. PALONIS, ESQ. PA ID NO 205703 CHROMULAK & ASSOCIATES, LLC 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, CIVIL DIVISION Successor in Interest to HSBC Bank USA, N.A., No. No. Of - Y/Sy ecL;-l Plaintiff, vs. Raphael Acevedo, Defendant. COMPLAINT AND NOW COMES, the Plaintiff, Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., by its Attorneys, Chromulak & Associates, LLC, with its Civil Action Complaint, the following of which is a statement thereof: 1. Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A. 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. Raphael Acevedo is an adult individual residing at 1162 Heron Court, Mechanicsburg PA 17050. 3. On or about July 7, 2006, Defendant entered into a written Loan Agreement with the Plaintiff, as evidenced by the Endorsed Check, 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 AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 January 28, 2008. 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, including principal and interest, and owing by the Defendant is in the sum of Eight Thousand One Hundred Twenty Five and 75/100 ($8,125.75) Dollars as of May 12, 2008. 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 attorney's fees. WHEREFORE, Plaintiff claims damages in the sum of Eight Thousand One Hundred Twenty Five and 75/100 ($8,125.75) Dollars, with interest thereon at the rate of 25.698% from May 13, 2008, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC Byj CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 TERESA K. FUCHS, ESQ. PA ID NO. 205696 JENNIFER M. PALONIS, ESQ. PA ID NO. 205703 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. i C5 r 0 O r 0 03 r ru -.7 r O I" r r r r ui r r ru 0 0 0 0 0 ? 1 w Sure- Q"O M s* ir-j0 oo?m h+%. -i 0 - _D 7Cm ,, 0 O Q. -j ,c moc? 00 0ruw C) o ? O - - + z Q t eo c A-Co xaW 10310000403 07/07/2006 0218798616 Io I a ?o 0 r 0 P 0 m i ru a 0 e r r •• r r r r i ? ?o w f. y V t ? i. i? •O O O 0 EXHIBIT ,A,, s ?N t^ z a '.r y Y o v w ? ? z D ! CT: con 1 . qj 0 a, cr egg 10 to m« -« d o^ ?? Tr IF ?s f 7Q a o ? N I ?y e 0 Z4 I ?? 031000040 07/07/2006 0216798616 031000040 07/07/2006 6111293369 *071000301* 07107/2006 6616650961 S a .?IMNNOOR Irfl??Hw?.le $? ?? i?et b0?d bes np?ld PAY sOSNE K ?{Ii6T t?J1SS T y2 4 IL N M ta-N lio v a•• to 0+ .? tU I A. cu rr ?.* If3 7r- i? s a MOO Oca a co O ?v v o tp i\ o opener 87634 M BW* NA ae9//1tl n teat Eap TOwar Road Be 8p0{? 71179406060000PR06w1u690IWW70W75F26.77247780387%341 N USA, R 70-7001 Ka16rHSBCm Q1wy HSBC µaF b= 0* June 19, 2006 ?a • Sample A. Sample AMOUNT: $7 000.75 SEVEN THOUSAND AND 75/100 DOLLARS ' Not 7117%47%34A77 after: July 19, 2006 QayNs Endorsement and Two Forms of ID Required. endorsing the back of this check you accept our offer and roe to the terms of your loan agreement contained in Form 6772PA(06/O6 477. If this offer is not accepted, please A4? destroy this check. Sample A. Sample Signing this check will result in a loan that June 2006 477CO10PABeneficial015 must be repaid with interest and fees. Wellsboro, PA 16901-1219 /?D III111111111111111111111111111111111t11111n11111111111111t1111 '•' ??'.tiOGrr._ AUTHORIZED SIGNATURE 11a0 i900404081N 1: 27 L9?00 L LI: ? L L?948?9634??u• Sign the back of this check, and cash or deposit it before the expiration date. Athens Township A Bwwfk sP 1892 Elmira Steel JlairRWC4DGAW Sayre PA 18840 Customer 1D No.: 477 8038796341 (570) 868-7796 Check Amount: $7,000.75 This is a real check for $7,000.75 It's valid until July 19, 2006 Dear Sample A. Sample, You can take this check to the bank! Once you cash it, you enter into a loan from Beneficial. Then you can use the money to make your family life even more rewarding. Take this check to your bank This is a real check, not a copy of one. So you can use it to get money fast, or simply deposit it in the bank. And, if you have any questions, you can call us at 1-866-396-INFO (4636). Use the money for anything You may want to make a large purchase. Or use it when you want ready cash for any unexpected expenses. No matter what, it's available now. It's easy to get more money Simply come in with your check and we'll add an extra $2,000 to our loan offer. Please visit our local branch at the address above before July 19, 2006. Sincerely, Azar,,- A ee.?A-z z-e Kevin Klingbeil Branch Manager, Beneficial P.S. To accept this loan offer, please be sure to sign and deposit your check before July 19, 2006. If you do not accept this loan offer, please remember to destroy the attached check. 10 - Day Satisfaction Guarantee-Because we want you to be completely satisfied, we offer a Satisfaction Guarantee. If for any reason you are not satisfied w? is loan and you repay it in full within 10 days after the loan funds are disbursed, other than with a refinance of this loan with us, we will refund charges, closing costs and fees. We will also waive any prepayment penalty applicable to your loan. any The Promissory Note and Disclosures found on the back contain a full explanation of the terms and conditions of your loan SPECIAL NOTICE - Please see the enclosed documents entitled "Privacy Statement" for important information on your rights. THIS IS A SOLICITATION FOR A LOAN - READ THE ENCLOSED DISCLOSURES BEFORE SIGNING THIS CHEM If you do not wish to receive any further solicitation, please call (570) 010.7796. You can choose to stop receiving "prescreened" offers of credit from this and other companies by calling toll-free 1-888-567-8688. See PRESCREEN & OPT-OUT NOTICE on other side for more information about prescreened offers. 26"VA(061.)177 015 19 711794(110 477/1/367%341-14009673745 477 y S== NONOW (no ae reene i 4i l acloeW nrq ey III F-ft a ?. d? EBESGRMN A ?E T-OLr* NOTICE- This "prescreened" offer of credit is based on iniormatlon in yoLw credit report kldicaHnthat you must meet certain criteria. This offer is not guaranteed N you do not meet our criteria [irduding prolfidYro saceptaWe Property as eo6tsrell. K you do not want to receive prescresnsd offers of credit from this aarna?? other companies, cant the conaumar g agencies toll-free, i-888-6t<7-B6e1? or write: TX 19. Opts,, P.O. TErans UniOcrt?, M'arketing OPt-Out,/ P O 1 Box 7gT328, Jackson MS 30208-7328. x 710129, Atlanta, OA 90374-0123, VKUM1550HY NOTE AND DISCLOSURES CREDITOR (Called "We", "Us", "Our"): Beneficial Conpaner Discount Company Amens Township 1892 Elmira Stoat Sayre, PA 18840 BORROWER (Called "You", "Your"): Sample A. Sample June 2006 477COt OPABene0cial015 Wekboro, PA 16901-1218 • ANNUAL P?ICEJRABE RATE • FtiIARCE IgIARgE Meant Flaaaad Tetd of iss"Wi is date The cost of your credit as a The dollar amount the credit The amount of credit The amount you will have Of yearly rate. will Cost you. provided to you or on paid after you have made all Lea 28.772SG $5.76645 your behalf. payments as scheduled. .e. $7,000.75 $12,780.20 Jose 10, 2000 e, Your Payment achedule WIN be: Frgayeuoeb O the pay eO arty, yes nay be wdtbed to a raOnd d part of 180 Fbam ChEW Labe Cow 11 yes dn't ply my pyaat Is 10 days altar ft's as, yes V11111 sin ply 1-1/2% Par sham as the ataeast werdes pleNat to a $IJM edslaw ?? See baba for any additional Inlon. Hon abed noreayment default, ry required repayment In U before the scheduled dale, and prepayment Wands and wastes. "o• mans an estimate Nulmlter of Payments Amount of Payments When F'symerute An Due: 80 $212.82 ? be0irminp on the Payment Due Date shown on the first Boling by the Rub of 78ths. amount you owe less, any unearned Finance Charges you would receive H you lacy prepaid, and (b) You will also pay our reasonable attorney ton. H the attorney, b not our Finance r "'e'""g are armcneo arseN, you apse to the farms of this Promissory Nob and Disclosure and promise to pay us the Told of Payments Ohs sum of t2urps plus the Amours Finarxxsd) in nnmhy payments as stated above, Fkurres CfurOe behMes a nonrefundable Service thwpe of $1.50 I« cad, t:5o00 or fractlon tluweW not to exceed s maximum of Et 50.00 and inluect which has been calculated In advance at the Contract Rsb of 25.699% per year on the scheduled unpaid balances on the assumptions the payments are mule on time. DATE ON WHICH FINANCE CHARGES BEGIN. PAYMENT DATES. This loon will be o«atnrNrded on the date you cash the check for the ban proceeds which you received with this Promissory Note and Disclosures. Finance Charges will begin on the dale the check Is cashed. PREPAYMENT. H you tiny pay before the final payment due date. the amount you owe will be reduced by unearned Finance Charges (hut not the Service Charge) determined LATE CHARGE H you don't pay any payment In 10 days elver tt's due, you will also pay 1-1/2'16 per month an the amount overdue (subject to s $1.00 minimum charge). BAD CHECK CHARGE We will charge you a fa of $20 if any payment Bich b rohaned because of insufficient holds or is otherwise dishonored. flea spa that we may deduct this charge from a monthly payment FAILURE TO PAY. H you don't pry any payment on time (a) at your Payments may become due at once and without notifying you before Winphrp sutt, we may we for the total employee. for legal proceedings to collect this loan «roarw on security. ALTERNATIVE DISPUTE RESOLUTION. Tema of the Arbitration Provision is provided with Hrb Promissory Nob and Dbdoetae and Is Incorporated herein by reference. CUSTOMER INFORMATION PRACTICES. You apes that the Department of Moir Vehicles (« your state's equivalent of such department) may release your residence address to us, shoWd It become necessary to locals you. Vou apes that our supervisory parsanrd may Men to telephone eels between you and our repraesntaHves in order to evaluate the quaay, of our service to you. For more Information regarding o« privacy pracHcss, please rotor to the enclosed Pdvacy Statement ITEMIZATION OF AMOUNT FINANCED. The emhs Amount Financed (shown above) will be given directly to you. 879634-PA-471-051204 2?A(OTil06)477 PA0456.07 VMMCATION Patricia L. Hughes ; Recover Specialist for BENEFICIAL CONSUMER DI$COUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A. 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 coa ect to the best of her knowledge, information and belief- Patricia L. Haghes t i ha 21 71 eT.`a ? 4Y ? INII ^^ `` 1= SHERIFF'S RETURN - REGULAR CASE NO: 2008-04154 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS ACEVEDO RAPHAEL STEVE BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon the DEFENDANT , at 0018:05 HOURS, on the 1st day of August , 2008 at 1162 HERON COURT MECHANICSBURG, PA 17055 RAPHAEL ACEVEDO DEFENDANT a 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 Service Affidavit Surcharge by handing to 18.00 12.00 .00 10.00 V `IV . VV Sworn and Subscibed to before me this day of I _ So Answers: R. Thomas Kline 08/04/2008 CHROMULAK & ASSOCIATES By: eputy Sheriff A. D. .0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO 'HSBC BANK USA, N.A., CIVIL DIVISION No. 08-4154-CIVIL Plaintiff, vs. ' RAPHAEL ACEVEDO, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 1162 HERON COURT MECHANICSBURG, PA 17050 Dated: SEPTEMBER 3, 2008 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. TYPE OF PLEADING: Praecipe for Default Judgment TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A. COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQUIRE /PA ID NO. 42067 V BETH ARNOLD HOWELL, ESQUIRE PA ID NO. 203606 TERESA K. FUCHS, ESQUIRE PA ID NO. 205696 JENNIFER M. PALONIS, ESQUIRE PA ID NO. 205703 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 TO: PROTHONOTARY Please enter judgment by default against the within-named defendant, RAPHAEL ACEVEDO, for failure to file an Answer as follows: Amount Claimed in Complaint: $8,125.75 Interest from, 5/13/08 through 9/03/08: 642.06 Costs of Collection through 9/03/08: 532.50 TOTAL $9,300.31 With interest accruing on the total balance of $9,300.31 at the rate of 6% per annum, together with additidnal costs of suit. BY CATHY ANN CHROMULAK, ESQUIRE BETH ARNOLD HOWELL, ESQUIRE TERESA K. FUCHS, ESQUIRE JENNIFER M. PALONIS, 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 WASHINGTON SS: Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared, ?5z fn old-Hp?oe)A , ESQUIRE, attorney for and authorized representative of plaintiff who, being duly sworn according to law, deposes and says that the defendant is not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed to defendant on AUGUST 22, 2008 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attached copy. Sworn to and subscribed before me This day ofl 2008. Notary Public wOMMONWEALTH OF PENNSYLVHNi, Notarial Sea! Heather L. Hatfield, Notary Public Cecil Twp., Washington County My Commission E)ires June 29, 2010 ., Y.^ U? .xni;?=fat. .I:.! •i--. CATHY ANN CHROMULAK, ESQUIRE BETH ARNOLD HOWELL, ESQUIRE TERESA K. FUCHS, ESQUIRE JENNIFER M. PALONIS, ESQUIRE 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, Successor in Interest to HSBC Bank USA, N.A. ' Plaintiff, VS. Raphael Acevedo Defendant. TO: Raphael Acevedo 1162 Heron Court Mechanicsburg PA 17050 DATE OF NOTICE: August 22, 2008 CIVIL DIVISION No. 08-4154-Civil 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 RAPORTANT 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 By: •??.?-?Rr -?? CATHY ANN CHROMULAK, ESQ. BETH ARNOLD HOWELL, ESQ. TERESA K. FUCHS, ESQ. JENNIFER M. PALONIS, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4te Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. A lJt ? ? } o Z> O t? -' OR g w y 9` t 0 0 w cc) 3 g3 . a awit V IL $ v . aye, '3 - ? G? a •o 9 $ a O O° ? m C31 G a 9, q N 00" w n 4. r4 N o?'O= ran r,) x .i 1o?m OD G TO W * 0 6' D m v na c? a ex+ cn rn c-n _ D : v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT CIVIL DIVISION COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., No. 08-4154-CIVIL vs. Plaintiff, RAPHAEL ACEVEDO, Defendant. NOTICE OF ORDER DECREE OR JUDGMENT TO: RAPHAEL ACEVEDO 1162 HERON COURT MECHANICSBURG, PA 17050 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ?T? 15T???D Q () A copy of the Order or Decree is enclosed, or THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. (X) The judgment is as follows: 12,12-0.-3 -1 lus interest at the rate of 6% per annum and additional costs of suit. r?. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., vs. RAPHAEL ACEVEDO, and PATRIOT FCU, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Plaintiff, Defendant, CIVIL DIVISION No. 08-4154-CIVIL TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT Garnishee. COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A. Defendant's Address: 1162 HERON COURT MECHANICSBURG, PA 17050 Garnishee's Address: 247 OVERCASH AVE. CHAMBERSBURG, PA 17201 Date: JANUARY 15, 2009 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 TERESA K. FUCHS, ESQ. PA ID NO. 205696 JENNIFER M. PALONIS, ESQ. PA ID NO. 205703 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4`h Floor Canonsburg, PA 15317 (724) 916-2400 r e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., Plaintiff, vs. RAPHAEL ACEVEDO, Defendant, and PATRIOT FCU, Garnishee. CIVIL DIVISION No. 08-4154-CIVIL PRAECIPE FOR WRIT OF EXECUTION TO: The Prothonotary Please issue a Writ of Execution in the above matter, I . directed to the Sheriff of FTiANKLIN County; 2. against RAPHAEL ACEVEDO, defendant, and 3. against PATRIOT FCU, garnishee, 4. and index this writ a. against RAPHAEL ACEVEDO, defendant, and b. against PATRIOT FCU, 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 -joint, personal and business. 5. Amount of Judgment Additional Interest to Date (Costs to be added) $9,300.31 $ 189.10 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. $9,489.41 CATHY ANN CHROMULAK, ESQ. BETH ARNOLD HOWELL, ESQ. TERESA K. FUCHS, ESQ. JENNIFER M. PALONIS, ESQ. 04 -43 C c 0' 4 ?, c Q ) t Ito 1 CIZ> cz-3 -n ?. ss - N TI t N V' 74 r V - l WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-4154 Civil CIVIL ACTION - LAW TO THE SHERIFF OF FRANKLIN COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., Plaintiff (s) From RAPHAEL ACEVEDO, 1162 HERON COURT, MECHANICSBURG, PA 17050 (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 PATRIOT FCU, 247 OVERCASH AVE., CHAMBERSBURG, PA 17201 - ALL MONIES DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $9,300.31 Interest TO DATE - $189.10 Atty's Comm % Atty Paid $159.50 Plaintiff Paid Date: JANUARY 20, 2009 L.L. $.50 Due Prothy $2.00 Other Costs - 64, is C is R. Long, rothonot (Seal) By: 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 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., Plaintiff, VS. Raphael Acevedo, and Patriot FCU, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant(s), Garnishee. CIVIL DIVISION: No. 08-4154-CIVIL TYPE OF PLEADING: Praecipe to Settle & Discontinue Against Garnishee ONLY TYPE OF CASE: Civil Action FILED ON BEHALF OF: Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A. COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 TERESA K. FUCHS, ESQ. PA ID NO. 205696 JENNIFER M. PALONIS, ESQ. PA ID NO. 205703 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4"' Floor Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., Plaintiff, VS. Raphael Acevedo, and Patriot FCU, Defendant(s), Garnishee. CIVIL DIVISION: No. 08-4154-CIVIL PRAECIPE TO SETTLE & DISCONTINUE AGAINST GARNISHEE ONLY TO THE PROTHONOTARY: Please settle & discontinue this action against the above garnishee, Patriot FCU, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By: X CATHY ANN CHROMULAK, ESQ. BETH ARNOLD HOWELL, ESQ. TERESA K. FUCHS, ESQ. JENNIFER M. PALONIS, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4"' Floor Canonsburg, PA 15317 Sworn to and subscribed Before me this _ ^ day of , 2009. Notary P, THIS IS AN ATTEMPT TO ? COMMONWEALTH OF PENNSYLVANIA Notarial Seat Heather L Hatfield, Notary Public f Cecil Twp., Washington County My Commission Expires June 29, 2010 ',"ember Pennsvlveri Assns!»' nn nt Nnrnries t yJ lV _ /?r COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, counsel for Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., hereby certify that a true and correct copy of the foregoing Praecipe to Settle & Discontinue Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 9th day of March 2009. Patriot FCU P.O. Box 778 Chambersburg, PA 17201-0778 Raphael Acevedo 1162 Heron Court Mechanicsburg, PA 17050 tom.. Cathy Ann Chromulak, Esq. Beth Arnold Howell, Esq. Teresa K. Fuchs, Esq. Jennifer M. Palonis, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Sk4 .. _ o ? _ ?? - 7 a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., VS. RAPHAEL ACEVEDO, and FIRST CLASS FCU, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Plaintiff, Defendant, CIVIL DIVISION No. 08-4154-CIVIL TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT Garnishee. COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A. Defendant's Address: 1162 HERON COURT MECHANICSBURG, PA 17050 Garnishee's Address: 510 BUSINESS PARK LANE ALLENTOWN, PA 18109 Date: AUGUST 3, 2009 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 TERESA K. FUCHS, ESQ. PA ID NO. 205696 JENNIFER M. PALONIS, ESQ. PA ID NO. 205703 CHROMULAK & ASSOCIATES, L.L.C. 401 Technology Drive Suite 202 Canonsburg, PA 15317 (724) 916-2400 t and IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., Plaintiff, VS. RAPHAEL ACEVEDO, FIRST CLASS FCU, TO: The Prothonotary Defendant, Garnishee. CIVIL DIVISION No. 08-4154-CIVIL PRAECIPE FOR WRIT OF EXECUTION Please issue a Writ of Execution in the above matter, 1. directed to the Sheriff of LEHIGH County; 2. against RAPHAEL ACEVEDO, defendant, and 3. against FIRST CLASS FCU, garnishee, 4. and index this writ a. against RAPHAEL ACEVEDO, defendant, and b. against FIRST CLASS FCU, 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 joint, personal and business. 5. Amount of Judgment Additional Interest to Date (Costs to be added) Less 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. $9,300.31 - $45'r• T t $ 571.49 $ 642.60 $9,229.20 CATHY ANN CHROMULAK, ESQ. BETH ARNOLD HOWELL, ESQ. TERESA K. FUCHS, ESQ. JENNIFER M. PALONIS, ESQ. .000 FiLED--t l=" %;E OF THE ! ' ,n^ \OTARY 2009 AUG -S P 1: 09 ?a.+?. soar d1? ,yp, oc? Cos+?• if 1?•UV ? rl aV. SG ,? / S9 . so q;j.©d & ?,p? Rr41 ?=?-- ?28ssd WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 084154 Civil CIVIL ACTION - LAW TO THE SHERIFF OF LEHIGH COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., Plaintiff (s) From RAPHAEL ACEVEDO,1162 HERON COURT, MECHANICSBURG, PA 17050 (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 FIRST CLASS FCU, 510 BUSINESS PARK LANE, ALLENTOWN, PA 18109 - SAID WRIT OF EXECUTION IS PURSUANT TO ALL MONIES DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $8,657.71 Interest $571.49 Atty's Comm % Atty Paid $189.50 Plaintiff Paid Date: AUGUST 5, 2009 (Seal) L.L. Due Prothy $2.00 Other Costs A/ PJ-1A -1 1? - Curtis R. Long, Prothonotary By: '047-a? - Deputy REQUESTING PARTY: Name TERESA K. FUCHS, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 401 TECHNOLOGY DRIVE SUITE 202 CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 205696 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., Plaintiff, VS. RAPHAEL ACEVEDO, Defendant, CIVIL DIVISION 08-4154-CIVIL No . . co TYPE OF PLEADING: 1 C-) _ Praecipe to Discontinue i? . o 0r1 Against Garnishee ONLY Cn TYPE OF CASE: AND FIRST CLASS FEDERAL CREDIT UNION, Garnishee. Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 ,.-?ETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 TERESA K. FUCHS, ESQ. PA ID NO. 205696 JENNIFER M. PALONIS, ESQ. PA ID NO. 205703 CHROMULAK & ASSOCIATES, L.L.C. 401 Technology Drive Suite 202 Canonsburg, PA 15317 (724) 916-2400 8.00 PQ rmY CV-1t Igo-30 0# a3'7yg9 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, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., Plaintiff, Vs. RAPHAEL ACEVEDO, and Defendant, FIRST CLASS FEDERAL CREDIT UNION, Garnishee. CIVIL DIVISION No. 08-4154-CIVIL PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please discontinue this action against the above garnishee, FIRST CLASS FEDERAL CREDIT UNION and mark the docket accordingly. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Heather L. Hatfield, Notary Public Cecil Twp., Washington County My Commission Expires June 29, 2010 Member, Pennsylvania Association of Notaries Sworn to and subscrib d Before_ne this day of , 2010. Notary Public Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By:oL11? CA HY ANN CHROMULAK, ESQUIRE BETH ARNOLD HOWELL, ESQUIRE TERESA K. FUCHS, ESQUIRE JENNIFER M. PALONIS, ESQUIRE Attorneys for Plaintiff 401 Technology Drive Suite 202 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, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., 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 3rd day of February, 2010. FIRST CLASS FEDERAL CREDIT UNION 510 BUSINESS PARK LANE ALLENTOWN, PA 18109 RAPHAEL ACEVEDO 1162 HERON COURT MECHANICSBURG, PA 17050 Cathy Ann Chromulak, Esq. Beth Arnold Howell, Esq. Teresa K. Fuchs, Esq. Jennifer M. Palonis, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.