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HomeMy WebLinkAbout04-1211IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. LARRY BRADY a.k.a. LARRY C. BRADY, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 39 Red Tank Road Boiling Spring, PA 17007 CIVIL DIVISION No. Oq -- I, ll 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 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 THI$1$ 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. CIVIL DiVISION No. LARRY BRADY a.k.a. LARRY C. BRADY 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 b e 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 O R CANNOT AFFORD O NE, G O T O O R 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. LARRY BRADY a.k.a. LARRY C. BRADY, Plaintiff; Defendant. CIVIL DIVISION COMPLAINT AND NOW 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 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. LARRY BRADY a.k.a. LARRY C. BRADY is an adult individual residing at 39 Red Tank Road, Boiling Spring, PA 17007. 3. On or about June 17, 2003, Defendant entered into a written 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 November 7, 2003. 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 Nine Thousand and Three Hundred and Ninety-three and 26/100 ($9,393.26) Dollars as of February 6, 2004. 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, Plaintiffclaims damages in the sum of Nine Thousand and Three Hundred and Ninety-three and 26/100 ($9,393.26) Dollars, with interest thereon at the rate of 24% from February 6, 2004, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page I of 4) LENDER (called "We", "Us", "Our"} 'HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY 25 GATEWAY DRIVE GATEWAY SOUARE/SUITE 107 MECHANICSBURG PA 17055 BORROWERS (called "You", "Your") BRADY, LARRY SS# 165380282 39 RED TANK RD BOLLING SPRI PA~13007 LOAN NO: 319303-10-126326 f .N~NUAL .01 AND OVER 2.000 % ~ 24.000 I 8600 06117/0:~ O0 , 50, O0 In this Agreement, "you", "your" and "Borrower" mean the customer(s) who signs this Agreement. "We", "us", and "our" refer to Lender. This Agreement covem the terms and conditions of your Personal Credit Linc Account. We want you to understand how your Personal Credit Line Account works. Read this carefully, ask us any questions, and if you agree to be bound by this Agreement, sign below, If more than one person signs, each will be responsible for repaying all sums advanced under this Agreement. Your Credit Line Account is a revolving line of credit extended to you and secured as described below. You can obtain funds from your Personal Credit Line Account (up to your credit limit) directly from us or by using the specia} checks Wc supply to you. You may pay your total unpaid balance at any t;mc or in installments. REQUIRED INSURANCE. You must obtain insurance for term of loan covering security for this loan agreement as indicated by the word "YES" b~low, naming us as Loss Payee: Physical damage insurance on vehicle listed under "Security" above, if "Y" appears under "Insured." O3-Ol-O0 PA056361 PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 2 of 4) Available Credit: You may obtain funds directly from us or through your special checks up to your available credit. Each check must be written for at least $100.00. Your available credit is your credit limit (shown on page one) less the total unpaid balance, ~ncludlng Finance Charges, of your Account. If you make loan payments by check, we will adjust yocr available credit seven days after we receive your check to allow for check clearing. If you request funds in an amount that would cause you to exceed your available credit, we arc not obligated to honor your request. If we do lend you an amount over yonr available credit, you agree to pay us that excess amount, plus Finance Charges, immediately. Promise to Pay: You promise to pay L~nder: la) amounts borrowed under this Agreement; (b) Finance Charges, Admmmtrat~ve L. harges (the late charge and bad check charge) and other charges provided in this Agreement; (c) credit insurance charges, it' any; (d) collection costs permitted by applicable law, including reasonable attorneys' fees: and amounts in excess of your credit limit that we may lend you, plus Finance Charges. Payments: You may repay your entire outstanding balance at any time without penalty. You may not use your special charles to pay any amounts doe under this Agreement. Because the Finance Charge ia computed each day, you will contact os regarding the exact payoff amount for the day you intend to make full payment. If you do not pay the entire unpaid balance on your Account at once, you agree to pay at least the minimum payment shown on your monthly statement. Payments will be applied as follows: First, to any accrued but unpaid Finance Charges; Second, to any unpaid Administrative Charges (the lat~ charge and bad check charge); Third, to any unpaid credit insurance charges; and Fourth, to the outstanding balance of your Account. Any part of your monthly payment to be applied to amounts borrowed on your Account will be applied to the amounts borrowed under your Personal Credit Line Account in the order in which The amounts were borrowed. Any part of your monthly payment to be applied to Finance Charges will be applied in the same Minimum Monthly Payment: The Minimum Monthly Payment for any billing cycle will be the greater of (1} the greater of $2.5 or the Yayment Amount (aa described below) plus any Administrative Charges and credit insurance charge, rounded to the nearest $1: or (2) the Finance Charges due for the billing cycle plus any Administrative Charges and credit insurance cbarges; or (3) the amount of the Annual Fee assessed to your Account. In each instsnee the Minimum Monthly Payment will be adjusted to include any unpaid amounts due from previous billing cycles. The Payment Amount depends on the monthly periodic rate applicable to your Account, and is calculated as follows: Monthly Periodic Rate through 1.33% over 1.33% through 1.45% over 1.45% through 1.57% over 1.57% through 1.70% over 1.70% through 1.83% over 1.83% through 1.95% over 1.95% Payment Amount 1.43% of Account Balance 1.55% of Account Balance 1.67% of Account Balance 1.80% of Account Balance 1.93% of Account Balance 2.00% of Account Balance 2.15% of Account Balance Finance Charges: This is the interest charged on the balance of your Account during each Nlling cycle. The Finance Charge la calculated from the date that each advance, check or charge is posted to your Account· '/'he Finance Charge is computed by multiplying the average daily balance in your Account in each billing cycle times the monthly periodic rate stated on page one. The average daily balance is determined by totaling all daily unpaid balances in each hilling cycle and dividing the total by the number of days in that cycle (but not leas than thirty). A daily unpaid balance is the amount owed each day, excluding any unpaid Finance Charge, Administrative Charges, and credit insurance charges for prior billing cycles. "'Annual Fee: You agree to pay an Annual Fee as stated on page one for participation in this revolving credit plan. The Initial Annual Fee is stated on page one and {a due and payable on the date that your Account is established, and the subsequent Annual Fee stated on page one is duo and payable on the same day of each subsequent year. You agree that this fee may be charged to your Account balance. Bad Check Charge: If you pay by a check which is returned for any reason, you agree to pay a bad check charge of $20. Late Charge: If you do not pay any required Minimum Monthly Payment within 15 days after it is due, you agree to pay a late charge of 10% of the Minimum Monthly Payment due or $20, whichever is greater (excluding any unpaid late charges and amounts due from prior billing cycles). NOTICE: SEE THE FOLLOWING PAGES FOR ADDITIONAL PROVISIONS ANO IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPL,~E BILLING ERRORS. o.o,-oo F NRE PERSONAl. CREDIT LINE ACCOUNT AGRI?.EMENT {Page 3 of 4) Other Charges: You agree to pay any amounts actually incurred by Lender for services rendered in connection with the Personal Credit Lina Account for fees paid to public officials in connection with perfecting, recording, releasing or satisfying a security interest in the security. You agree that these fees may be charged to your Account balance, Exchange of Information: You understand that from time to time we may receive credit information concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a regular basis, we obtain related to your Account, including but not limited to credit reports and insurance information, with any of our affiliated corporations, subsidiaries or other third parties. The uses of this information may include an inquiry to determine if you qualify for additional offers of credit. You also authorize us to share any information regarding )'our Account with any of our affiliated corporstions, subsidiaries or other third parties. You may prohibit the sharing of such information {except for the sharing of information about transaclions or experiences between us and you) by sending a written request which contains your full name, Social Security Number and Address to us at P.O. Box 1547, Chesapeake, VA 23.;20. If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent of such department) may release your residence address to us, should it become necessary to locate you. You agree that our supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the quality of our service to you. Termination and Changes in the Agreement: We can terminate your right to obtain additional advances or cl~ange thc terms of tll~s Agreement, ~nclodmg increasil~g thc rate of Financc Charge at any time. Prior written notice will be given to you when rcquircd by applicable lan' unless you consent to the change before that time. Changes may apply to both new and outstanding balances unless prohibited by applicable law. Default and Cancellation of Agreement: Wc have thc right to require you to pay your entire balance plus all other accrued but unpaid charges immediately and/or to cancel your credit pri¥ilcgea under this Agreement because of: (a) failure to make any payments in full when duc under this Agreement; (b) frequent overdrawing of your line of credit; {c) failure to supply us with any information requested; {d) supplying us with misleading, false, incomplete or incorrect information; {e) breaking any of the promises, terms or conditions that are contained in this Agreement; {f) the filing of a bankruptcy petition by or against you; (g) the death of any borrower who signs this Agreement; or (h) the sale or transfer of any interest in the property securing this agreement (this includes the creation of a subordinate lien). After default, you will pay our court costs, reasonable attorney fees (if attorney is not our salaried employee), and other collection costs related to the default, if not prohibited by applicable law. Any balance outstanding under this Agreement when the credit limit is terminated will continue to accrue interest at the contract rate until paid in full. YOUR BILLING RIGHTS KEEPTIIIS NOTICE FOR FUTURE USE This notice contains important imformatlon about your rights and Lender's responsibilities under the Fair Credit Billing Act. Notify Lender In Case of Errors or (~uestions About Your Bill If you think your bill is wrong, or if you need more information about a transaction on your bill, write Lender on a separate sheet at the address listed on )'our bill after the words: "Send your billing error notice to: {Lender's, name and address)." Write to Lender as soon as possible. Lender must hear from you no later than 60 days after Lender sent you the first bill on which the error or problem appeared. You can telephone Lender, but doing so will not preserve your rights. NOTICE: SEE THE FOLLOWING PAGE FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. 03-01-00 PAD563a~' PERSONAL CREDIT LINE ACCOUNT AOREEMENT (Page 4 of 4} In your letter, give [~nder the following information: · Your name and account number. * The dollar amount of the suspected error. s D~scribe the error and explain, if you can, why you believe there is an error. If you need more information, describe the item you are not sure about. Your Rights and Lender's Responsibilities After Lender Receives Your Written Notice Lender must acknowledge your letter within 30 days, unless Lender has corrected the error by then. Within 90 dsys, Lender must either correct the error or explain why Lender believes the bill was correct. After Lender receives your letter, Lender cannot try to collect any amount you question, or report you es delinquent. Lender can continue to bill you for the amount you question, including financ~ charges, and Lender can apply any unpaid amount against your credit limit. You do not have to pay any qt~stioned amount while Lender is investigating, but you are still obligated to pay the parts of your bl]l that are not in question. If Lender finds that Lender made a mistake on your bill, you will not have to pay any finance charges related to any questioned amount. If Lender did not make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, l.~nder will send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount that L~nder thinks you owe, I.~nder may report you as delinquent. However, if Lender's explanation does not satisfy you and you write to Lender within ten days telling Lender that you still refuse to pay, l.znder must tell anyone Lender reports you to that you have a question about your hill. And, Lender must tell you the name of anyone Lender reported you to. Lender must tell anyone Lender reports you to that the matter has been settled between us when it finally is. If Lender doesn't follow these rules, Lender can't collect the first $50 of the questioned amount, oven if your hill was correct Alternative Dispute Resolution and Other Riders: The terms of the Arbitration Agreement and any other Riders signed as part of thru loan transaction am incorporated rote this Agreement by reference. Applicable Law: The terms and conditions of this Agreement will be governed by the provisions of the Pennsylvania Consumer l)tacount Company Act, Chapter 7, Sections 6201 through 6221, Purdon's Pennsylvania Statutes Annotated, particularly Section 6217.1. Before signing this Agreement, you have read and received this Agreement and the Federal Truth-In-Lending disclosures contained in it. You, the customer(s) signing below, agree to observe the terms and conditions of this Agreement. This Agreement is entered under the applicable provisions of Federal law and the Pennsylvania Consumer Discount Company Act. tome(/'Signature ~/ (SEAL) (SEAl.) Customer Signature ])ate: (SEAL) (SEAL) 03-01-00 PA0563G4 aL F NRE VERIFICATION Dawn Richt, Recover Specialist for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, A HOUSEHOLD INTERNATIONAl, COMPANY Deposes and says subject to the penalties of 1 g Pa C.S. Section 4904 relating to unswom 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. Dawn Richt SHERIFF'S RETURN - CASE NO: 2004-01211 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERIJtND HOUSEHOLD FIN~CE CONSUMER VS BRADY LARRY AKA LARRY C BRADY REGULAR JODY SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania who being duly sworn according to says, the within COMPLAINT & NOTICE was served upon BRADY LARRY AKA LARRY C BRADY the DEFENDANT at 0856:00 HOURS, on the 29th day of March , 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to LARRY BRADY a true and attested copy of COMPLAINT & NOTICE law, together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: ..00 Service .00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 28.00 03/29/2004 CHROMULAK & ASSOCIATES Sworn and Subscribed to before me this 3~ day of ~ SL~Q W A. D .~ By: Deput~ Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, VS. Plaintiff, LARRY BRADY a.k.a LARRY C. BRADY, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION No. 04-12][ 1 TYPE OF PLEADING: Praecipe For Entry Of Consent To Judgment TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Defendant's Address: 39 RED TANK ROAD BOILING SPRING PA 17007 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA 1D NO. 42067 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 J 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. LARRY BRADY a.k.a Defendant. LARRY C. BRADY, CIVIL DIVISION No. 04-1211 PRAECIPE FOR ENTRY OF CONSENT TO JUDGMENT TO PROTHONOTARY: Please enter judgment in favor of Plaintiff, HOUSEHOLD FiNANCE CONSUMER DISCOUNT COMPANY and against Defendant, LARRY BRADY a.k.a LARRY C. BRADY, in the amount ofTEN THOUSAND, THREE HUNDRED FOUR AND 34/100 ($10,304.34), with interest thereon at the legal rate of 6% from MARCH 7, 2004, as evidenced by the Consent to Judgment attached hereto as Exhibit A. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. Scott E. Crawford, Esq. THISI$ 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, CIVIL DIVISION No. 04-1211 Vs. Plaimiff, LARRY BRADY a.k.a LARRY C. BRADY Defendant. CONSENT TO JUDGMENT t of A~allNOart~W.e, to ~i~ this ~:t~-t~'' .day of ~3 ~' ' [ ,2004, with the consen o a p ies an eir respec ire counsel, it is agreed as follows: Judgment shall be and is hereby entered against Defendant LARRY BRADY a.k.a LARRY C. BRADY in the amount of TEN THOUSAND, THREE HUNDRED FOUR AND 34/100 ($10,304.34) DOLLARS plus interest on the unpaid balance at the rate of 6% per annum commencing on MARCH 7, 2004. Defendant LARRY BRADY a.k.a LARRY C. BRADY agrees to make payments to Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY in the amount of TWO HUNDRED FORTY-TWO AND 00/100 ($242.00) DOLLARS on or before the 20TH day of each month for FORTY-NINE (49) consecutive months, until the entire debt owing Plaintiffis paid in full. The first payment shall be due on or before APRIL 20, 2004. Payments shall be sent to Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY in care of Chromulak & Associates, L.L.C., 375 Southpointe Boulevard, 4th Floor, Canonsburg, PA 15317, or any other address Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY may later desigrtate. Defendant LARRY BRADY a.k.a LARRY C. BRADY has induced Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, and Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOLrNT COMPANY agrees to forbear in the enforcement of its rights against him/her so long as Defendant LARRY BRADY a.k.a LARRY C. BRADY makes timely payment. If Defendant LARRY BRADY a.k.a LARRY C. BRADY fails to make timely payment, then Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY may institute or take all steps necessary, appropriate or helpful to collect the judgment, represented hereby, together with the Plaintiff's costs of collection and attorneys fees therefore. AND NOW, on the date written above, the parties set forth their hands and seals as follows: Witness LARRY B'ILADY a.k.a LAR~Y C. BRADY Scott E. Crawford, t~ttorney for Plaintiff THIS IS AN ATTEMPT TO I COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Scott E. Crawford, Esquire, counsel for Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a tree and correct copy of the foregoing PRAECIPE FOR ENTRY OF CONSENT TO JUDGMENT was served upon the following by United States First Class Mail, postage prepaid on this ~9q'6~ day of ,2004: LARRY BRADY a.k.a LARRY C. BRADY 39 RED TANK ROAD BOLLING SPRING PA 17007 Scott E. Crawford, Esq. 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. LARRY BRADY a.k.a. LARRY C. BRADY, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION No. 04-1211 TYPE OF PLEADING: Praecipe to Satisfy Judgment 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 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpoime Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 THIS IS AN A'I-I'EMPT 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. LARRY BRADY a.k.a. Defendant. ARRY C. BRADY, CIVIL DIVISION No. 04-1211 PRAECIPE TO SATISFY JUDGMENT TO PROTHONOTARY: Please satisfy the judgment against LARRY BRADY a.k.a. LARRY C. BRADY, at No. 04-1211, and mark the docket accordingly. MY Commission Exl~res Janua~ 15, 2007 Member, Pennsvk. anto Assodef~m Of No~aries Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. CATHY ANN CIt[ROMULAK, ESQ. PA ID NO. 42067 SCOTT E. CRAWFORD, ESQUIRE PA ID NO. 89570 Sworn to and subscribed Before me this C9~ $* day of h~.,~ ,2004. Notary Public Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 THISIS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL EIE 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 Satisfy Judgment was served upon the following by First Class Mail, postage prepaid on this 21st day of May, 2004. LARRY BRADY a.k.a. LARRY C. BRADY 39 RED TANK ROAD BOILING SPRING, PA 17001 cott E. Crawford, igsq. THISIS AN A'I'I'EMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.