HomeMy WebLinkAbout04-1905IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. QL( - 1QQ6
TYPE OF PLEADING:
Complaint
TYPE OF CASE:
Civil Action
?lVLI. l?/
Plaintiff,
VS.
KRISTIE A. FOREMAN
a.k.a. KRISTIE FOREMAN,
Defendant.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
11 Riddle Road
Camp Hill, PA 17011
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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
4'h Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff, CIVIL DIVISION
Vs.
No.
KRISTIE A. FOREMAN
a.k.a. KRISTIE FOREMAN
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 L AWYER O R C ANNOT A FFORD 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 CIVIL DIVISION
DISCOUNT COMPANY, nn
No.
Plaintiff,
VS.
KRISTIE A. FOREMAN
a.k.a. KRISTIE FOREMAN,
Defendant.
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. KRISTIE A. FOREMAN a.k.a. KRISTIE FOREMAN is an adult individual
residing at 11 Riddle Road, Camp Hill, PA 17011.
3. On o r about April 2 9, 2 003, D efendant e ntered i nto 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 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 November 28, 2003.
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, and owing by the
Defendant is in the sum of Five Thousand, Three Hundred and Eighty-six and 83/100
($5,386.83) Dollars as of March 17, 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, Three Hundred
and Eighty-six and 83/100 ($5,386.83) Dollars, plus court costs and attorney's fees.
Respectfully submitted,
Chromulak & Associates, LLC
f64
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CATHY ANN CHROMULAI{, ESQ.
PA ID NO. 42067
SCOTT E. CRAWFORD, ESQ.
PA ID NO. 89570
Attorneys for Plaintiff
375 Southpointe Boulevard
41h Floor
Canonsburg, PA 15317
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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EXHIBIT
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PROMISSORY NOTE AND DISCLOSURES
CREDROR (Called'We,'Us','Oun
New•, , Fkmnd• Camuma Gbcsunt cempeay
MaOMW Tome or
26111Maamllmr Rd
WYNNY, PA 1N62
• ANNLIae PERCFNTAC.F • FINANCE CHARC.F
RATE The dolumllWM tlY Credit
TMWal Dl youreredaua wa wee Yw_
ye" road,
n.+w%
You Paymme schedule drill be:
Nuedear of Payments I Anlounl of Payments
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earnpleA "neple
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W.. PA 1246
Annum Financed Total of Paylnw(1 Date
TheamounlWcredY TM and,% you we have Of
pmvkeo W you or on pad after you have mad. A Loan
Your Mhal. potentials as sc;hwhred,
e is.wa,w 110,1911.011, ... an" 21. MI
Wlmn Payments M Dan:
Monthly, beginning on the Payment Due Dale shown on w Find ailing
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NM aiNmam olmr{ay
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-e moon an meneen
PROMME TO PAY. By alynkg Ore deeded Hack, you dgrde W Ma brmc M Ink Pmmksory None ark Dkdoem and POmke ad Pay u an Tend a p.y.m,, (eve ..,v at
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ted-w-ing you fm 1W.. dMa oedn.
DATE ON WNICN FNMICE CNARGEG 6EGPd. PAYMENT DATES. Th4 bn W M cmnummabtl do na dale yw men 1M check ror tln ben prxeeM rlrkh yw rFCMwed
wire tldsPmMawry Noe end DYWeum, FNameCMrpmHbpNan na dmelM DlNCIrYaehad.
PREPAYMENT. Fym IDN pair bMon ne Mnt prymaM dm dM, na amwnl you owe M M reduced by ummn•d FhmrNe CMrOaa (Md ml me eenke Chdrpe) delxmMO
by ne Rune of TNhe.
LATE CHARGE. a yeu don't pay vnypdymaM N 10 days after are dm. You wa dka pry 1-ItM ar moon move amwrd evardue (wbiw We 4.61 mNhnum dh.M.).
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deemed Mind an ded,dity.
KTERYNTNE DISPUTE REBOLUTpN. Tamm W dm AAbaMn Provkbn Y provked wan nY PrwYeny NMe ud OYcbeun Y hrDarOdnW herein by Menme
Fl L4YMIdOE OF NFORWTION. Wd mry aeere YRdrlrmlorl aemd you INdudkp MI rent ee1W b Naurenw Mmmmllen ant NlmmaMn abbYred kvm male repodirq aGemka)
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22d1wdad ant eMli • raeaent.
CREDIT REPORTNG. ttYw hyro IWIa rev Yma Mymu crWY obhpatlon. • mgvlke none reNCINp an your creel rdcoM maY M wOmDatl b • crMa nporlMq dOwcY- Ym
may no* w al P.O. 6.1150Q. Ehnnunl. IL 611215 F Ym Emkre w have reported Nadcurab Momenta regmGNg your account he • .,.od redrew
ITEMIZATIONOFAMOUNTFINANCED.ThedreadA MFhrenmd(eh..beve)we MYkmdeeclybyou.
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9EP 23 2003 10 13 FR MOLLICA RNO MIRRAY
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4123817111 TO 8510400000MI81 P.02i02
VEWIC9TION
I, Angela Davis, Sr. Clerk for
HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, A HOUSEHOLD INTERNATIONAL COMPANY.
Angela Davis
verity that the facts set forth in the foregoing Complaint are true and correct to the best of
my knowledge, infotmation and belief, and that I am authorized to verify such Complaint
on behalf of HOUSEHOLD
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
4904 relating to unworn falsitle adon to authorities.
Dated: APRIL 27, 2004
** TnTPA PeN.'C.P;7 **
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-01905 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS
FOREMAN KRISTIE A AKA KRISTIE
RON KERR
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within NOTICE
was served upon
FOREMAN KRISTIE A AKA KRISTIE FOREMAN the
DEFENDANT , at 0017:59 HOURS, on the 3rd day of May 2004
at 11 RIDDLE ROAD
CAMP HILL, PA 17011 by handing to
KRISTIE A. FOREMAN
a true and attested copy of NOTICE together with
COMPLAINT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 11.04
Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
39.04 05/04/2004
CHROMULAK 7SePIATE'
Sworn and SSubscribed to before By: me this day of uty (heri??ff
A.D. v
?` ;??Prothonotary
THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
No. 04-1905 Civil Term
CIVIL DIVISION
Plaintiff,
vs.
KRISTIE A. FOREMAN
a/k/a KRISTIE FOREMAN,
TYPE OF PLEADING:
Praecipe for Default Judgment
TYPE OF CASE:
Defendant.
Plaintiffs Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
11 Riddle Road
Camp Hill, PA 17011
Dated: June 7, 2004
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Civil Action
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQUIRE
PAID NO. 42067
MAUREEN A. DOWD, ESQUIRE
PA ID NO. 90549
SCOTT E. CRAWFORD, ESQUIRE
PA ID NO. 89570
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4"' Floor
Canonsburg, PA 15317
(724) 916-2400
TO:PROTHONOTARY
Please enter judgment by default against the within-named defendant, KRISTIE A.
FOREMAN a/k/a KRISTIE FOREMAN, for failure to file an Answer as follows:
Amount claimed in Complaint: $5,386.83
Interest from 3/18/04 through 6/07/04: -0-
Costs of Collection through 6/07/04: 503.54
TOTAL $5,890.37
With interest accruing on the total balance of $5,890.3 7 at the rate of 6% per annum, together
with additional costs of suit.
BY
CATHY5MULAK, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
SCOTT E. CRAWFORD, 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 ALLEGHENY
SS:
Before me, the undersigned authority, a Notary Public in and for said County and State,
personally appeared SCOTT E. CRAWFORD, ESQUIRE, attorney for and authorized
representative o f p laintiff w ho, b eing d my s worn a ecording t o t aw, d eposes a nd s ays t hat the
defendant is not in the military service of the United States of America to the best of his
knowledge, information and belief and certifies that the Notice of Intent to take Default
Judgment was mailed to defendant on May 25, 2004 by certificate of mailing in accordance with
Pa.R.C.P. 237.1, as evidenced by the attached copy. EC
CATHY iAtNQN4CHROMULAK, ESQUIRE
MAUREEN A. DOWD, ESQUIRE
SCOTT E. CRAWFORD, ESQUIRE
Sworn to and subscribed before me
This_V'?,_ day of (/ 2004.
THIS IS AN ATTEMPT TO
/Notary Public COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
ac ?; r isy p.,?{;;• ;
n, jh Alleghq n,, 0o?jnty
?u 8xp+r.•. Jan. "?`,2)o5
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff,
Vs.
KRISTIE A. FOREMAN a.k.a.
KRISTIE FOREMAN
Defendant(s)
CIVIL DIVISION
No. 04-1905 CIVIL TERM
TO: KRISTIE A. FOREMAN
a.k.a. KRISTIE FOREMAN
I 1 RIDDLE ROAD
CAMP HILL, PA 17011
DATE OF NOTICE: MAY 25, 2004
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 IMPORTANT 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 or 800-990-9108
By: .fblajQar-
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CATHY ANN CHROMULAK, ESQ.
SCOTT E. CRAWFORD, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4ch Floor
Canonsburg, PA 15317
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THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
KRISTIE A. FOREMAN
a/k/a KRISTIE FOREMAN,
Defendant.
CIVIL DIVISION
No. 04-1905 Civil Term
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: KRISTIE A. FOREMAN
a/k/a KRISTIE FOREMAN
11 Riddle Road
Camp Hill, PA 17011
(X) Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above
captioned proceeding on J/ " CI , 'r Jn6 c .
O A copy of the Order or Decree is enclosed, or
(X) The judgment is as follows: $5,890.37 plus interest at the rate of 6% per
annum and additional costs of suit.
Deputy
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 04-1905 CIVIL TERM
Plaintiff,
vs.
KRISTIE A. FOREMAN a/k/a
KRISTIE FOREMAN,
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
Defendant,
and
MEMBERS FIRST CREDIT UNION,
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
11 RIDDLE ROAD
CAMP HILL, PA 17011
Garnishee's Address:
1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Date: JUNE 17, 2004
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
SCOTT E. CRAWFORD, ESQ.
PA ID NO. 89570
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4`h Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
KRISTIE A. FOREMAN a/k/a
KRISTIE FOREMAN,
Defendant,
and
MEMBERS FIRST CREDIT UNION,
Garnishee.
CIVIL DIVISION
No. 04-1905 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
TO: The Prothonotary
Please issue a Writ of Execution in the above matter,
1. directed to the Sheriff of CUMBERLAND County;
2. against KRISTIE A. FOREMAN a/k/a KRISTIE FOREMAN, defendant, and
3. against MEMBERS FIRST CREDIT UNION, garnishee,
4. and index this writ
a. against KRISTIE A. FOREMAN a/k/a KRISTIE FOREMAN, defendant, and
b. against MEMBERS FIRST CREDIT UNION, 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)
$5,890.37
$ 8.82
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.
$5,899.19
Seof
SCOTT 4CRA RD , ESQ.
A
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-1905 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY, Plaintiff (s)
From KRISTIE A. FOREMAN A/K/A KRISTIE FOREMAN, 11 RIDDLE ROAD, CAMP HILL,
PA 17011
(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 MEMBERS FIRST CREDIT UNION, 1166 WALNUT BOTTOM ROAD, CARLISLE, PA
17013 - 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 $5,890.37
Interest $8.82
Arty's Comm %
Arty Paid $121.04
Plaintiff Paid
Date: JUNE 21, 2004
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothonotary ?^/
By: o L? .c7?,,-?
Deputy
REQUESTING PARTY:
Name SCOTT E. CRAWFORD, ESQUIRE
Address: CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD
4Tn FLOOR
CANONSBURG, PA 15317
Attorney for: PLAINTIFF
Telephone: 724-916-2400
Supreme Court ID No. 89570
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-01905 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS
FOREMAN KRISTIE A AKA KRISTIE
And now ROBERT BITNER ,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0013:25 Hours, on the 25th day of June , 2004, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
FOREMAN KRISTIE A AKA KRISTIE FOREMAN in the
hands, possession, or control of the within named Garnishee
MEMBERS 1ST CREDIT UNION 1166 WALNUT BOTTOM ROAD
SLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BRIAN PETERS (BRANCH MANAGER)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to His
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
So answe s
R. Thomas Kline
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
this ? day of
thonotary
By S
D uty She. ff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
CIVIL DIVISION
No. 04-1905 CIVIL TERM
VS.
KRISTIE A. FOREMAN a/k/a KRISTIE
FOREMAN,
TYPE OF PLEADING:
Praecipe to Discontinue
Against Garnishee ONLY
Defendant,
and
MEMBERS FIRST CREDIT UNION,
Garnishee.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
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
MELISSA A. SHENKEL, ESQ.
PA ID NO. 91445
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4ch 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.
KRISTIE A. FOREMAN aWa KRISTIE
FOREMAN,
Defendant,
and
MEMBERS FIRST CREDIT UNION,
Garnishee.
CIVIL DIVISION
No. 04-1905 CIVIL TERM
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
Please discontinue this action against the above garnishee:, MEMBERS FIRST CREDIT
UNION and mark the docket accordingly.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By:
CAT Y ANN CHROMULAK, ESQUIRE
MELISSA A. SHENKEL. ESQUIRE
Attorneys for Plaintiff
375 Southpointe Boulevard
0 Floor
Canonsburg, PA 15317
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE. USED FOR THAT PURPOSE.
Sworn to and subscribed
Before me this _ fM day
of r66 2005.
CERTIFICATE OF SERVICE
I, Melissa A. Shenkel, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY, 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 day of February, 2005.
MEMBERS FIRST CREDIT UNION
P.O. BOX 40
MECHANICSBURG, PA 17055
KRISTIE A. FOREMAN a/k/a
KRISTIE FOREMAN
1 I RIDDLE ROAD
CAMP HILL, PA 17011
Mel' sa A. Shenkel, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
-tcs,
v't -v
z"
c`?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
PLAINTIFF,
VS.
KRISTIE A. FOREMAN, A/K/A
KRISTIE FOREMAN,
DEFENDANT.
Dated: ? IZZ iv5-
CIVIL DIVISION:
No. 04-1905
TYPE OF PLEADING:
MOTION TO COMPEL ANSWERS
TO INTERROGATORIES IN AID OF EXECUTION
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK PA ID No. 42067
MELISSA A. SHENKEL PAID No. 91445
CHROMULAK & ASSOCIATES, L.L.C.
375 SOI.InworINTE BouLEvARD
4' FLOOR
CANONSBuiG, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
PLAINTIFF,
VS.
KRISTIE A. FOREMAN, A/K/A
KRISTIE FOREMAN,
DEFENDANT.
CIVIL DIVIISION:
No. 04-1905
MOTION TO COMPEL ANSWERS TO INTERROGATORIES IN AID OF EXECUTION
AND NOW, comes the Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY, by and through its attorneys, Chromulak & Associates, L.L.C., and moves this Court
for an Order, pursuant to Pa.R.Civ.P. 4019, to compel the Defendant, KRISTIE A. FOREMAN,
a/k/a KRISTIE FOREMAN, to respond to interrogatories and in support thereof avers as follows:
1. Judgment for Plaintiff and against Defendant was entered on June 7, 2004 in the sum
of $5,890.37.
2. Plaintiff served interrogatories upon Defendant, via first class mail on August 12,
2004. A true and correct copy of the interrogatories are attached hereto as Exhibit "A" and
incorporated herein by reference.
3. Pursuant to Pa.R.Civ.P. 4006 (a)(2), Defendant's responses to the interrogatories
were due within thirty (30) days after they had been served.
4. A demand letter was sent via first class mail on. December 27, 2004. A true and
correct copy of the demand letter is attached hereto as Exhibit "B" and incorporated herein by
reference.
5. As of the date of this Motion, no responses have been received from the Defendant.
6. Plaintiff requires an Order pursuant to Pa.R..Civ.P. 4019(a)(1)(i) compelling
Defendant to answer the interrogatories.
WHEREFORE, Plaintiff respectfully requests the Cow-t to approve the proposed Order
annexed hereto.
t?
CATHY ANN Ci- ROMULAK PA ID 42067
MELISSA A. SIIENKEL PA ID 91445
CHROMULAK & ASSOCIATES, L.L.C.
375 SoUTHPOINTE BOULEVARD
4' FLOOR
CANONSBURG, PENNSYLVANIA 15317
(724) 916-2400
(734) 916-2411 (FACSMI[LE)
DATED: (0 /Z Z 1p'5-
2
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
PLAINTIFF,
vs.
KRISTIE A. FOREMAN
A.K.A. KRISTIE FOREMAN,
DEFENDANT.
August 12, 2004
You are Hereby Notified to Plead to the
Enclosed Interrogatories Within 30 Days
From Service Hereof or a Default
Judgment May Be Entered Against You.
Ste* V'aw"-o
Attorney for Plaintiff
CIVIT, DIVTSI, :
No. 04-1905 CIVIL TERM
TYPE OF PT,FADTNf:;
INTERROGATORIES IN
AID OF EXECUTION DIRECTED TO
DEFENDANT KRISTIE A. FOREMAN
A.K.A. KRISTIE FOREMAN
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
CATHY ANN CHROMULAK PA ID No. 42067
ScoTr E. C:RAwFORD PAID No. 89570
HEATHER C. TROXEL PA ID No. 91848
CHROMULAK & ASSOCIATES LLC
375 Southpointe Blvd.
4'h Floor
Canonsburg, PA 15317
(724) 916-2400
EXHIBIT
W THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
PLAINTIFF,
vs.
KRLsTIE A. FOREMAN
A.K.A. KRISTIE FOREMAN,
DEFENDANT.
CrVTT. I)TVISM:
No. 04-1905 CIVIL TERM
INTERROGATORIES IN AID OF EXECUTION DIRECTED TO DEFENDANT KRISTIE A. FOREMAN
A.K.A. KRISTIE FOREMAN
TO: Kristie A. Foreman a.k.a. Kristie Foreman
11 Riddle Road
Camp Hill, PA 17011
AND NOW COMES, Plaintiff, Household Finance Consumer Discount Company, by their
attorneys, Chromulak & Associates LLC, and herewith files and serves on Defendant the following
Interrogatories, to be answered by Defendant under oath within thirty (30) days in accordance with
the Rules of Discovery of the Pennsylvania Rules of Civil Procedure. (Space has been provided,
but if such space is insufficient for a complete Answer, please complete Answer on a separate sheet
and attach hereto.)
1. What is your full legal name?
ANSWER:
2. What is your current address?
ANSWER:
3. Are you employed? Who is your employer? (name all employers)
ANSWER:
4. What is your annual salary or hourly pay?
ANSWER:
5. Do you have any other sources of income? If yes, describe all sources of additional income
in detail.
ANSWER:
6. Are you married?
ANSWER:
7. Do you own or have any interest in any land/real estate? If yes, briefly describe the
land/real estate (i.e. address) and the ownership interest you possess.
ANSWER:
2
8. If anyone is assisting you in answering these interrogatories, state his or her name,
relationship to you, and address.
ANSWER:
9. What savings, checking and money market accounts do you own or have any interest in?
ANSWER:
a.
b.
C.
d.
10. What Individual Retirement Account (IRA) do you own?
ANSWER:
a.
3
11. Do you own or have interest in a safety deposit box? If yes, describe the location and the
contents of the safety deposit box.
ANSWER:
12. Do you belong to a credit union or other work related savings plan? If yes, describe.
ANSWER:
13. What stocks, shares, bonds, notes and shares in a mutual funds do you own or have an
interest in?
ANSWER:
T=P, (i a share, honds =.) Name of romoratio a Current Bal
a.
b.
14. Does any individual, partnership, or corporation owe you money? If yes, provide details of
the debt.
ANSWER:
4
15. Do you own life insurance? If yes, list the insurance company and policy number.
ANSWER:
16. What televisions, stereos, VCRs, camcorders, cameras or other electronic/camera
equipment do you have in interest in?
ANSWER:
17. What household furnishings do you have an interest in?
ANSWER:
18. What jewelry do you own or have an interest in?
ANSWER:
19. What firearms do you own or have an interest in?
ANSWER:
5
20. What coins, stamps or other collectibles do you own or have an interest in?
ANSWER:
21. What other personal property (not previously described) do you own or have an interest in?
ANSWER:
22. What other assets (not previously described) do you have an interest in?
ANSWER:
23. If, in the preceding six years, you have transferred any assets (real property, personal
property), to any person, and/or, if you have given any gift valued at more than $250.00, of any
asset, including money, to any person; set forth, in detail, a description of the property, the type of
transaction, the date of occurrence and the name and address of the transferee or recipient.
ANSWER:
6
24. Is any of your property rented to, leased to or otherwise in possession of a third person? If
so, state full description of the property; the name and address of the person, firm, or other entity
who has possession of the property; the circumstances and reason why the property is in possession
of the third person; the consideration or payment received by you; the name and address of the
person who receives the rents or other consideration on behalf of you.
ANSWER:
25. State whether or not you own or have any rights in any motor vehicles. Include a full
description of each such motor vehicle including color, model, title number, serial number and
registration plate number. Also show the name or names in which each motor vehicle is registered,
the present value of each motor vehicle and their present location and place of regular storage,
garaging or parking. State also whether or not there are any encumbrances on those motor vehicles
and if so, the name and address of the encumbrance holder, the date of the encumbrance, the
original amount of that encumbrance, the present balance of the encumbrance and the transaction
which gave rise to the existence of the encumbrance. If not owned, state the extent of your rights in
and to such vehicles.
ANSWER:
26. What money have you received within the last sixty days from any source, and what have
you done with it? Identify sources.
ANSWER:
24f
CATHY ANN CI-IROMULAK PA ID 42067
SCOTT E. C]R.awFORD PA ID 89570
HEATHER C. TROXEL PA ID 91848
CHROMULAK & ASSOCIATES LLC
375 SOUTHI'OWTE BLVD
4"{FLOOR
CANONSBURG, PA 15317
(724) 916-2400
(724) 916-2411
AUGUST 12, 2004
I, Scott E. Crawford, counsel for Household Finance Consumer Discount Company, hereby
certify that a true and correct copy of the foregoing Interrogatories in Aid of Execution were
served via U.S. First Class Mail on the following, this LL"day of , 2004:
Kristie A. Foreman aka. Kristie Foreman
11 Riddle Road
Camp Hill, PA 17011
Scott E. Crawford
CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD
4"i FLOOR
CANONSBURG, PENNSYLVANIA 1.5317
TELEPHONE (724) 916-2400 FACSIMILE (724) 716-2418
Melissa A. Shenkel
Attorney- At-Law
Direct Dial: (724) 916-2418
mshenkel@chromulak.com
December 27, 2004
Kristie A. Foreman a/k/a Kristie Forman
11 Riddle Road
Camp Hill, PA 17011
RE: Household Finance Consumer Discount Company vs. Kristie A. Forman
a/k/a Kristie Forman
No. 04-1905 Civil Term; Cumberland County, Pennsylvania
Dear Ms. Forman:
On August 12, 2004, my office sent a set of Interrogatories to you that were to be
answered and returned within thirty (30) days. As of the date of this letter, my office has
received no response. I have enclosed a copy of the interrogatories that were previously mailed
to you. Please return the answered interrogatories to my office no later than January 7, 2005. If
my office does receive these papers from you by the date indicated, we may proceed with further
legal action against you.
Very truly yours,
LISSAISHE
MAS/dmr
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
EXHIBIT
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
PLAINTIFF,
VS.
KRISTIE A. FOREMAN, A/K/A
KRISTIE FOREMAN,
DEFENDANT.
Dated: (o I Z 2
CIVIL DIVISION:
No. 04-1905
TYPE OF PLEADING:
MEMORANDUM OF LAW IN SUPPORT OF
MOTION TO COMPEL ANSWERS
To INTERROGATORIES IN AID OF EXECUTION
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK PA ID No. 42067
MELISSA A. SHENKEL PA ID No. 91445
CHROMULAK & ASSOCIATES, L.L.C.
375 SoUTHFoINTE BOULEVARD
4T" FLOOR
CANONSBURG,PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
PLAINTIFF,
VS.
KRISTIE A. FOREMAN, A/K/A
KRISTIE FOREMAN,
DEFENDANT.
CIVIL DIVISION:
No. 04-1905
MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL
ANSWERS TO INTERROGATORIES IN AID OF EXECUTION
FACTS AND INTRODUCTION
Plaintiff commenced this action alleging non-payment of a loan agreement entered into by
the parties. Judgment for Plaintiff and against Defendant was entered on June 7, 2004 in the amount
of $5,890.37. Plaintiff served interrogatories upon Defendant, via first class mail on August 12,
2004. Pursuant to Pa.R.Civ.P. 4006 (a)(2), Defendant's responses to the interrogatories were due
within thirty (30) days after they had been served. A demand letter was sent via first class mail on
December 27, 2004. As of the date of this Motion, no responses have been received from the
Defendant. Plaintiff requires an Order pursuant to Pa.R.Civ.P. 4019(a)(1)(i) compelling Defendant
to answer the interrogatories.
ARGUMENT
Rule 4019(a)(1)(i) of the Pennsylvania Rules of Civil Procedure provides that a "Court may,
on motion, make an appropriate order if a party fails to serve answers, sufficient answers or
objections to written interrogatories under Rule 4005". Rule 400:5 requires that the answering party
serve answers to written interrogatories with in thirty days of the service of the interrogatories.
As the interrogatories were served to the Defendant on or about August 12, 2004 and as the
Defendant has, to date, failed to answer the interrogatories, this Court should enter the proposed
Order attached to Plaintiff s Motion to Compel.
CONCLUSION
For the reasons set forth above, this Court should enter the proposed Order attached to
Plaintiffs Motion to Compel Answers to Interrogatories, and compel Defendant to answer said
mterrogatones.
CATHY ANN CHROMULAK PA ID 42067
MELISSA A. SHENKEL PA ID 91445
CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHI,OINTE BOULEVARD
4T" FLOOR
CANONSBURG, PENNSYLVANIA 15317
(724) 916-2400
(734) 916-2411 (FACSrnm.E)
DATED: (p X22 (6)"1"
CERTIFICATE OF SERVICE
I, Melissa A. Shenkel, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY, hereby certify that a true and correct copy of the foregoing Motion to Compel
Answers to Interrogatories In Aid of Execution and Memorandum of Law was served, via United
States First Class mail, postage prepaid, on the following, this ZZKi day of
a,J ur_#, 2005:
KRISTIE A. FOREMAN
a/k/a KRISTIE FOREMAN
11 RIDDLE ROAD
CAMP HILL, PA 17011
Melissa A. Shenkel
r
? ^p i?T7
T
?
?
Y
r n
i
` C-11
w
HOUSEHOLD FINANCE
CONSUMER DISCOUNT
COMPANY,
Plaintiff
V.
KRISTIE A. FOREMAN, :
a/ka/ KRISTIE FOREMAN:
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 04-1905 CIVIL TERM
ORDER OF COURT
AND NOW, this 6`h day of July, 2005, upon consideration of Plaintiff's Motion To
Compel Answers to Interrogatories in Aid of Execution, a Rule is hereby issued upon
Defendant to show cause why the relief requested should not be granted.
RULE RETURNABLE within 20 days of the date of this order.
athy Ann Chromulak, Esq.
Melissa A. Shenkel, Esq.
375 Southpointe Boulevard
4`h Floor
Canonsburg, PA 15317
Attorneys for Plaintiff
istie A. Foreman
&Wa Kristie Foreman
11 Riddle Road
Camp Hill, PA 17011
Defendant, pro se
b?
:rc
BY THE COURT,
i io
?S ;Z 'aid L- lAr 5061
lb!(U C i? ,u :,,Hl JO
3NO-Gllj
Household Finance Consumer
Vs
Kristie A. Foreman
Writ of Execution
Docket No. 2004-1905 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED. No action has been taken in the last six months.
Sheriffs Costs
Docketing $18.00
Surcharge $20.00
Levy $20.00
Mileage $ 3.45
Poundage $ 1.44
Prothonotary $ 1.50
Garnishee $ 9.00
Total $73.39 r/
So Answers:
R. Thomas Kline, Sheriff
BY G{?- Lam(
Sergeant
1 V
CA- 7 3 a '/,?
/?" d 3 3 3 Jt,