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HomeMy WebLinkAbout08-73655 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company Plaintiff, CIVIL DIVISION Vs. No. Owil o. og - 7 3(o5 term Charles Hollingsworth a/k/a Charles Hollingsworth Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth 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. S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, CIVIL DIVISION Plaintiff, vs. Charles Hollingsworth a/k/a Charles Hollingsworth Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth, Defendants. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendants' Address: 117 Allen Court Camp Hill, PA 17011 THIS 13 AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 444- No. D?- ?3L5 ?r TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: Beneficial Consumer Discount Company 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, LLC 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, CIVIL DIVISION Plaintiff, No. vs. Charles Hollingsworth a/k/a Charles Hollingsworth Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth, Defendants. COMPLAINT AND NOW COMES, the Plaintiff, Beneficial Consumer Discount Company, by its Attorneys, Chromulak & Associates, LLC, with its Civil Action Complaint, the following of which is a statement thereof: 1. Beneficial 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. Charles Hollingsworth a/k/a Charles Hollingsworth Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth are adult individuals residing at 117 Allen Court, Camp Hill, PA 17011. 3. On or about August 30, 2004, Defendants entered into a written Loan Agreement with the Plaintiff, a copy of which is attached hereto as "Exhibit A" and incorporated herein. 4. Pursuant to the Loan Agreement with Defendants, Plaintiff advanced funds to the Defendants. THIS Is AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5. Defendants are 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 October 22, 2008. Prior to that, the last payment was received on or about June 18, 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 Defendants is in the sum of Eight Thousand Twenty One and 531100 ($8,021.53) Dollars as of December 15, 2008. 7. Numerous demands have been made upon Defendants by Plaintiff, but Defendants have 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 Twenty One and 53/100 ($8,021.53) Dollars, with interest thereon at the rate of 17.999% from December 16, 2008, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC By:? b*-0j'AAHcpl., ? 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. LOAN REPAYMENT AND SECURITY AGREEMENT (Page 1 of 3) LENDER (called "We", "Us", "Our") BENEFICIAL CONSUMER DISCOUNT COMPANY 419 STONEHEDGE DRIVE SUITE 2 CARLISLE PA 17013 BORROWERS (called "You", "Your") LOAN NO: 5625 HOLLINGSWORTH JR , CHARLES SS# 4516 HOLLINGSWORTH, CAROLYN SS# 0590 117 ALLEN CT CAMP HILL PA 17011 REQUIRED INSURANCE. You must obtain insurance for term of loan covering security for this loan as indicated below, naming us as Loss Payee: Tick insurance on real estate Piro and extended coverage ini Physical damage insurance on Physical damage insurance on You may obtain any required in%, (See "Security" paragraph above for e if "Y" appears under "Insured". A ?? rity" above if "Y" appears under "Insured". be insured.) 05-01-04 NRE PAB75021 11178008238685CEA2000PA8750210""HOLLINGSWORTH If ORIGINAL LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3) PAYMENT. In return for this loan, you will pay us the Total of Payments (the sum of Finance Charges plus Amount Financed), in monthly payments stated on page one. The Finance Charge is the total of Interest plus Service Charge. You may pay more at any time. You will pay us at our business address as stated on page one or other address given you. If more than one Borrower is named on page one, we may enforce this Agreement against all, or any, Borrowers, but not in a combined amount greater than the amount owed. DATE ON WHICH FINANCE CHARGE BEGINS. Finance Charges begin on the date of disbursement. If this loan is made by mail, the date on which the Finance Charge begins is postponed by the number of days from the date of this Agreement to the date of disbursement. Payment due dates and effective date of any optional insurance purchased are also postponed. PAYOUTS. You agree to pay-outs of Amount Financed as shown on Truth-In-Lending disclosure form. If payouts change because loan closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check will be reduced to cover additional payouts. PREPAYMENT. If you fully pay before final payment due date, the amount you owe will be reduced by unearned Finance Charge (but not Service Charge) determined by the "Rule of 78ths". MATURITY. After the final payment due date stated on page one you will pay interest at the rate of 18% per year. SECURITY. You agree to give us a security interest in the property identified on page one, which will secure all indebtedness, including future advances under this Agreement. LATE CHARGE. If you don't pay any payment in 10 days after it's due, you will also pay 1 112% per month on the amount overdue (subject to a $1.00 minimum charge). BAD CHECK CHARGE. We will charge you a fee of $20 if any payment check is returned because of insufficient funds or is otherwise dishonored. You agree that we may deduct this charge from a monthly payment. FAILURE TO PAY. If you don't pay any payment on time or fail to keep any required insurance in force, (a) all your payments may become due at once and without notifying you before bringing suit, we may sue for the total amount you owe less any unearned Finance Charges you would receive if you fully prepaid, and (b) you will also pay our reasonable attorney fees, if the attorney is not our salaried employee, for legal proceedings to collect this loan or realize on security. 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 your Account with any of our affiliated corporations, subsidiaries or other third parties. You may prohibit the sharing of such information (except for the sharing of information about transactions 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 23320. 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. INSURANCE. Optional credit insurance and any required insurance disclosures are attached to this Agreement and are incorporated herein by reference. ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDERS. The terms of the Arbitration Agreement and any other Riders signed as part of this loan transaction are incorporated into this Agreement by reference. APPLICABLE LAW. The Pennsylvania Consumer Discount Company Act (CDCA), Title 7, Purdon's Pennsylvania Statutes, governs this loan. NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS. 05-01-04 TYRE PA875022 10111,®1 w 1®®1111MINMN® i1 ¦1780082386a5CEA9000PA8750220N"HOLLINGSWORTH of ORIGINAL LOAN REPAYMENT AND SECURITY AGREEMENT (Page 3 of 3) YOU HAVE RECEIVED A COMPLETE COPY OF THIS AGREEMENT AND THE TRUTH-IN-LENDING DISCLOSURES. BORROWERS: EAL) L. EAL) WITNESS: (SEAL) 05-01-04 NRE PA075023 ¦178008238685CEA9000PA8750230MNHOLLINGMTH ¦ GRIGIML TRUTH-IN-LENDING DISCLOSURES (Page I of 2) LENDER (Called "We", "Our", "Us") BENEFICIAL CONSUMER DISCOUNT COMPANY 419 STONEHEDGE DRIVE SUITE 2 CARLISLE PA 17013 BORROWERS (Called "You", "Your") LOAN NO: HOLLINGSWORTH JR , CHARLES HOLLINGSWORTH, CAROLYN 117 ALLEN CT CAMP HILL PA 17011 5525 *ANNUAL a FINANCE Amount Total of Payment Date PERCENTAGE CHARGE Financed The amount you will of The amount of credit have paid after you Loan RATE The dollar amount provided to you or have made all pay- The cost of our credit the credit will cost y you. your behalf. meats as scheduled- . as a yearly rate. 28.341% # 9475.54 $ 11718.88 $ 21194.40 08/30104 Your payment schedule will be: Number of Payments Amount of Payments When Payments Are Due 1 $ 353.24 09130104 059 $ 353.24 Day 30 of each month thereafter. Late Charge: If you don't pay any payment in 10 days after it's due, you will also pay 1 112% per month on the amount overdue (subject to a $1.00 minimum charge). Prepayment: If you pay off early, you may be entitled to a refund of part of the Finance Charge. See the contract documents for any additional information about nonpayment, default, any required repayment in full before the scheduled date, and prepayment refunds. NOTICE: The following page(s) contain(s) additional information. 09-14-04 NRE TIL PABIO121 I®Ibis®??IM?M®®111??1?1?1®??11 ¦176001238665FED9000PAB161210""HOLLINGSWORTH ¦ ORIGINAL TRUTH-IN-LENDING DISCLOSURES (page 2 of 2) ITEMIZATION OF THE AMOUNT FINANCED CREDIT LIFE INSURANCE (PAID TO INSURANCE COMPANY) .............................5 808.14 CREDIT DISABILITY INSURANCE (PAID TO INSURANCE COMPANY) .......................5 911.36 CASH OR CHECK TO BORROWER .....................................................3 9999.35 Loan Fee .......................................................5 150.00 PREPAID FINANCE CHARGES (TOTAL) ...............................................5 150.00 AMOUNT FINANCED (EXCLUDING PREPAID FINANCE CHARGE) ............................5 11716.86 08-14-04 NRE TIL PAD18122 i®®rrrrr®rrrrrrrrrrr'rrrrrrr?r ¦1T800823868SFE09000PA0181220KKHOLLINMVORTH ORIGINAL VERIFICATION Carrie A. Radcliff , Recover Specialist for BENEFICIAL CONSUMER DISCOUNT COMPANY 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 correct to the best of her knowledge, information and belief. E S p 4 ,44 ri LU r r l r Gk"j J C71 ?{ a SHERIFF'S RETURN - REGULAR CASE NO: 2008-07365 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS HOLLINGSWORTH CHARLES ET AL KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon UnT T TTT(1QWnDr7U r'UAPT.RC Tl? AKA unT,T,TNC-,WORTH CHARLES the DEFENDANT , at 0016:22 HOURS, on the 22nd day of December-, 2008 at 117 ALLEN COURT CAMP HILL, PA 17011 by handing to WIFE OF DEFENDANT 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: Docketing 18.00 Service 12.60 Affidavit .00 Surcharge 10.00 .00 Sworn and Subscibed to before me this day of So Answers: etL IZI Thomas Klin 12/23/2008 CHROMULAK & ASSOCIATES By. A. D. CASE NO: 2008-07365 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS HOLLINGSWORTH CHARLES ET AL KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HOLLINGSWORTH CAROLYN L AKA HOLLINGSWORTH CAROLYN the DEFENDANT , at 0016:22 HOURS, on the 22nd day of December-, 2008 at 117 ALLEN COURT CAMP HILL, PA 17011 by handing to CAROLYN HOLLINGSWORTH DEFENDANT 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: Docketing Service Affidavit. Surcharge n 1/0 ?/0 9 So Answers: 6.00 .00 .00 10.00 R.TThomas Kline .00 16.00 12/23/2008 CHROMULAK & ASSOCIATES Sworn and Subscibed to By: before me this day of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Plaintiff, CIVIL DIVISION No. 08-7365-Civil Term vs. Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth, Defendants. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 TYPE OF PLEADING: Praecipe For Entry Of Consent To Judgment TYPE OF CASE: Civil Action FILED ON BEHALF OF: Beneficial Consumer Discount Company COUNSEL OF RECORD: Defendant's Address: 117 Allen Court Camp Hill, PA 17011 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 4th Floor Canonsburg, PA 15317 (724) 916-2400 M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, CIVIL DIVISION Vs. Plaintiff, No. 08-7365-Civil Term Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth Defendants. t-C? ONSENT TO JUDGMENT AND NOW, to wit, this ` day of4 ?l 2009, with the consent of all parties and their respective counsel, it is agreed as follows: 1. Judgment shall be and is hereby entered against Defendants Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth in the amount of Eight thousand six hundred fifty-seven and 80/100 ($8,657.80) DOLLARS plus interest on the unpaid balance at the rate of 6% per annum commencing on January 7, 2009. 2. Defendants Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth agree to make an initial payment of $706.00 Dollars to Plaintiff Beneficial Consumer Discount Company on or before the 25th day of January 2009 and thereafter monthly payments in the amount of $353.00 on or before the 25`h day of each month until the entire debt owing Plaintiff is paid in full. The first $353.00 payment shall be due on or before February 25, 2009. Payments shall be sent to Plaintiff Beneficial Consumer Discount Company in care of Chromulak & Associates, L.L.C., 375 Southpointe Boulevard, 41t' Floor, Canonsburg, PA 15317, or any other address Plaintiff Beneficial Consumer Discount Company may later designate. 4. Defendants Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth have induced Plaintiff Beneficial Consumer Discount Company, and Plaintiff Beneficial Consumer Discount Company agrees to forbear in the enforcement of its rights against him/her so long as Defendants Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth make timely payment. If Defendants Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth fail to make timely payment, then Plaintiff Beneficial 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. EXHIBIT THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 4 AND NOW, on the date written above, the parties set forth their hands and seals as follows: Witness THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY MFORMATIOH 08TA; NED WILL i BE USED FOR THAT PURPOSE. Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. A, N .?. Carol Hollingsworth Carolyn L. Hollingsworth Cathy Ann Chromulak Beth Arnold Howell Teresa K. Fuchs Jennifer M. Palonis Attorneys for Plaintiff CERTIFICATE OF SERVICE I, counsel for Plaintiff, Beneficial Consumer Discount Company, hereby certify that a true 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 ILO- on this IfYM day of January 2009: Charles Hollingsworth aWa Charles Hollingsworth, Jr. Carolyn Hollingsworth aWa Carolyn L. Hollingsworth 117 Allen Court Camp Hill, PA 17011 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. Z Q Q r4 TUC -• y r j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, CIVIL DIVISION Plaintiff, VS. Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. and Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth, Defendants. No. 08-7365-Civil Term NOTICE OF ORDER, DECREE OR JUDGMENT TO: Charles Hollingsworth a/k/a Charles Hollingsworth, Jr. Carolyn Hollingsworth a/k/a Carolyn L. Hollingsworth 117 Allen Court Camp Hill, PA 17011 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above- captioned proceeding on i () A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: Eight thousand six hundred fifty-seven and 80/100 ($8,657.80), plus interest at the legal rate of 6% per annum and additional costs of suit. 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, Plaintiff, CIVIL DIVISION: vs. CHARLES HOLLINGSWORTH a/k/a CHARLES HOLLINGSWORTH JR. and C'AROLYN HOLLINGSWORTH a/k/a CAROLYN L. HOLLINGSWORTH, Defendant. Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. No. 08-7365-CIVIL TERM C- , '= -- CAS C1') " ? i ._,_ s a TYPE OF PLEADING: ;- u - , Praecipe to Satisfy Judgment ca TYPE OF CASE: -? - Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 ,_, ' TH 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 48.00 Pb A` -r`/ o- 1:59#74 p'*' g q6 la 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. CHARLES HOLLINGSWORTH a/k/a CHARLES HOLLINGSWORTH JR. and CAROLYN HOLLINGSWORTH a/k/a CAROLYN L. HOLLINGSWORTH Defendant. CIVIL DIVISION: No. 08-7365-CIVIL TERM PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please satisfy the judgment against CHARLES HOLLINGSWORTH a/k/a CHARLES HOLLINGSWORTH JR. and CAROLYN HOLLINGSWORTH alkla CAROLYN L. HOLLINGSWORTH, at No. 08-7365-CIVIL TERM, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By:D CL CATHY ANN CHROMULAK, ESQ. BETH ARNOLD HOWELL, ESQ. TERESA K. FUCHS, ESQ. JENNIFER M. PALONIS, ESQ. Attorneys for Plaintiff 401 Technology Drive Suite 202 Canonsburg, PA 15317 Sworn to and subscribed Before me this 2f-4- day of ?- '2010. Notary Public CAMMONINEALni OF PENN5YLVMIIA Notarial seal Heather L. Hatfield, Notary Pablk Cedl Twp., Wag*Vton County My CommMslon EVires June 29 2014 Member. PennsManla Assoddit d Notuks 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, hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy Judgment was served upon the following by First Class Mail, postage prepaid on this 21 ST day of SEPTEMBER, 2010. CHARLES HOLLINGSWORTH a/k/a CHARLES HOLLINGSWORTH JR. and CAROLYN HOLLINGSWORTH a/k/a CAROLYN L. HOLLINGSWROTH 117 ALLEN COURT CAMP HILL, PA 17011 Qck- 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.