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Home My WebLink About04-1344IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. THERESA L. FENERTY, Defendant. Plaintifff s Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION No. Oq-- 13q t TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Defendant's Address: 212 Myers Lane New Cumberland, PA 17070 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 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. CWIL DIVISION No. THERESA L. FENERTY 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. THERESA L. FENERTY, Plaintiff, Defendant. CIVIL DIVISION No. C)q-/3 q¥ 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. THERESA L. FENERTY is an adult individual residing at 212 Myers Lane, New Cumberland, PA 17070. 3. On or about January 15, 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 May 8, 2003. 6. Pursuant to the terms of the Loan Agreement, Plaintiff has the right to require payment of the entire amotmt owed upon default. The total amount due, and owing by the Defendant is in the sum of Five Thousand, Eight Hundred and Ninety-seven and 88/100 ($5,897.88) Dollars as of February 12, 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, Plaintiff claims damages in the sum of Five Thousand, Eight Hundred and Ninety-seven and 88/100 ($5,897.88) Dollars, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Ass~LC PA ID NO. 42067 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. --. 0 0 0 0 L~ 0 0 ADDRESS CORRECTION? Make Name PROMISSORY NOTE AND DISCLOSURES CREDITOR (Called "We", "Us", "Our~: BORROWER (Callsd 'You", 'Your"): · ~,HNIIAI PERCENTAGE - FINANCF CHARGE Amount Financ~ Total of Payments Date l, An~elaDavis, Sr. Clerkfor HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, A HOUSEHOLD INTERNATIONAL COMPANY. vertP2 chat th~ fa~ s~ forth in tho foregoing Complaint am tmc and correct to the best of my knowledge, information and bolir, f, Ired ~h~t I am authorized m wri~y suoh Complaint on behalf of HOUSEHOLD I undg~smad tha~ fals~ staIem~nia h~'ein ar~ mmic subj~t to tho penalties of 18 Pa. C.$. 4904 rel~ing m unswom falsifle~Ulon to amhoritics. Angel,. ]Davis MARCH 26, 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. THERESA L. FENERTY De~ndant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION No. 04-1344 CiVIL TERM TYPE OF PLEADING: Praecipe to Discontinue Without Prejudice TYPE O17 CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FiNANCE CONSUMER DISCOUNT COMPANY Date: April 2, 2004 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 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2,400 THISIS AN AI-I'EMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL I3E USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANy, Plaintiff, VS. THERESA L. FENERTY Defendant. CIVIL DIVISION No. 04-1.'-144 CiVIL TERM PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO: The Prothonotary: Please discontinue without prejudice the above-captioned action and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. CATHY ANN CHROMULAK, ESQ. PA ]]2) NO. 42067 SCOTT E. CRAWFORD, ESQUIRE PA ID NO. 89570 Sworn to and subscribed Before me this ~9,o day of ~/,e~L _, 2004. Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BI" USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Scott E. Crawford, ' Esqmre, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Discontinue without Prejudice was served upon the following by First Class Mail, postage prepaid on this 2nd day of April, 2003. THERESA L. FENERTY 212 MYERS LANE NEW CUMBERLAND, PA 17070 Scott E. Crawford,. Esq. -~-~15 I$ AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.