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HomeMy WebLinkAbout09-1021IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Household Finance Consumer Discount Company, Plaintiff, CIVIL DIVISION Vs. No. tA- IObU 'Wit le-"` Ronald E. Stine, 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 Household Finance Consumer Discount Company, Plaintiff, CIVIL DIVISION No. o 9 - / 6 d-I C ".'I -fe-6n vs. Ronald E. Stine, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 197 Skyline Drive Mechanicsburg, PA 17050 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 VdETH 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 Household Finance Consumer Discount CIVIL DIVISION Company, q d ?I G ?? I l/i. Plaintiff, No. ? / - I vs. Ronald E. Stine, 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. Ronald E. Stine is an adult individual residing at 197 Skyline Drive, Mechanicsburg, PA 17050, hereinafter referred to as "Defendant." 3. On or about October 29, 2007, the Defendant 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 Defendant, Plaintiff advanced funds to the Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATIONIOBTAINED 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 August 13, 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 Eleven Thousand Eight Hundred Sixty Two and 56/100 Dollars ($11,862.56) as of December 18, 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 Eleven Thousand Eight Hundred Sixty Two and 56/100 Dollars ($11,862.56), with interest thereon at the rate of 24% from December 19, 2008, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC By: 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" 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 1 of 4) LENDER (called "We", "Us", "Our") HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY 25 GATEWAY DRIVE GATEWAY SOUAREISUITE 101 MECHANICSBURG PA 11055 BORROWERS (called "You", "Your") LOAN NO; 5563 STINE, RONALD E S57k 4311 191 SKYLINE DR MECHANICSBUR PA 11050 ANNUM. NIONTKLV PERCENTAGE OF AVERAGE DAILY BALA CE PERIODIC RATE RATE. CREDIT LIMIT DATE OF LOAN 12100 1012910-7 01 AND OVER 2.000 % = 24 . 000 % INITIAL AINw EoUENT AM FEE 1 50.0011 50.00 In this Agreement, "you"', "your" and "Borrower" mean the customer(s) who signs this Agreement. "We", "us", and "our" refer to Lender. This Agreement covers the terms and conditions of your Personal Credit Line 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 special checks we supply to you. You may pay your total unpaid balance at any time 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" below, naming us as Loss Payee. Physical daTnage insurance on vehicle listed under "Security" above, if "Y" appears under "Insured." You may obtain any required insurance from anyone you choose. NOTICE SEE THE FOLLOWING. PAGES FOR ADDITIONAL PR EXHIBIT F MATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. IU I® 111110 It N, INNER PAOSS371 FSNRE-07 p "S6432973OA97RLA9000PA0563710RNST1 ORIGINAL 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 written for at least $100.00. Your available credit is your credit limit (shown on page one) less the total unpaid balance, including Finance Charges, of your Account. If you make loan payments by check, we will adjust your 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 are not obligated to honor your request. If we do lend you an amount over your available credit, you agree to pay us that excess amount, plus Finance Charges, immediately. Promise to Pay: You promise to pay Lender. (a) amounts borrowed under this Agreement; (b) Finance Charges, ministrauve arges (the late charge and bad check charge) and other charges provided in this Agreement; (c) credit insurance charges, if any; (d) collection costs permitted by applicable law, including reasonable attorneys' fees; and (e) 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 c ec to pay any amounts due under this Agreement. Because the Finance Charge is computed each day, you will contact us 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 late 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 manner. Minimum Monthly Payment: The Minimum Monthly Payment for any billing cycle will be the greater of (1) the $rea - or the Payment mount (as described-below) plus any Administrative Chargea-wnd-credit insurance charges, round to the nearest $4 or (2) the Finance Charges due for the billing cycle plus any Adlreffihdfst'ive Charges and credit insurance charges; or (3) the amount of the Annual Fee assessed to your Account. In each instance 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 t roug 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 o 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 billing cycle. The Finance Charge is ca cu ated from the date that each advance, check or charge is posted to your Account. The 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 billing cycle and dividing the total by the number of days in that cycle (but not less 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 Annuar Fee is stated on page one and is due and payable on the date that your Account is established, and the subsequent Annual Fee stated on page one is due 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 ate 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 AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. 05-20-07 PA056372 F NRE •S64329730A97RLA9000PA0563720ONSTINE ¦ DRIGINAL PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 3 of 4) Other Charges: You agree to pay any amounts actually incurred by Lender for services rendered in connection with the Personal It Line 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 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. Termination and Changes in the Agreement: We can terminate your right to obtain additional advances or Mange Me terms o t is Agreement, including increasing the rate of Finance Charge at any time. Prior written notice will be given to you when required by applicable law unless you consent to the change before that time. Changes may apply to both new and outstanding balances unless prohibited by applicable law. ii alt andd Cancellation of Agreement: We have. the sight to require you to p y kVr-entire balance plus all other accrue but unpal c arge immediately andfor to cancel your credit privileges under this Agreement because of: (a) failure to make any payments in full when due 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 KEEP THIS NOTICE FOR FUTURE USE This notice contains important imformation about your rights and Lender's responsibilities under the Fair Credit Billing Act. Notify Lender In Case of Errors or Questions 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 your 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. F;NRE-07 PA456373 rS6432973OA97RLA9000PA0563730x"STINE " ORIGINAL PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 4 of 4) In your letter, give Lender the following information: Your name and account number. The dollar amount of the suspected error. Describe 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 days, 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 as delinquent. Lender can continue to bill you for the amount you question, including finance charges, and Lender can apply any unpaid amount against your credit limit. You do not have to pay any questioned amount while Lender is investigating, but you are still obligated to pay the parts of your bill 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, Lender 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 Lender thinks you owe, Lender 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. Lender must tell anyone Lender reports you to that you have a question about your bill. And, Lender must tell you the name of anyone Lender reported ydu 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, even if your bill was correct Alternative Dispute Resolution and Other Riders: The terms of the Arbitration Agreement and any other Riders sign as part o this loan transaction are incorporat into this Agreement by reference. Applicable Law: The terms and conditions of this Agreement will be governed by the provisions of the Pennsylvania consumer iscount 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 low and the Pennsylvania Consumer Discount Company Act. This is a contract under seal and may be enforced under 42 PA.C.S. § 5529 (B). ??Lr (SEAL) ustomer ignature Date: /? 9 Q (SEAL) ustomer ignature Date: Witness: (SEAL) 05-20-07 RL F NRE "S6432973OA97RLA9000PA0563740*NSTINE (SEAL) PAOSS374 111111011 ORIGINAL LOAN CLOSING STATEMENT (Page I of 1) REVOLVING LOAN VOUCHER CREDITOR HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY 25 GATEWAY DRIVE GATEWAY SQUARE/SUITE 107 MECHANICSBURG PA 17055 BORROWERS STINE, RONALD E 197 SKYLINE DR MECHANICSBUR PA 17050 LOAN NO: - - '5563 Borrowers agree to and direct the disbursements and Advance indicated below. If any estimated amount shown below varies from the actual amount paid, Borrowers agree to the disbursement of the actual amount and a corresponding change to the Advance shown below. Borrowers agree that this Advance is made under Borrowers' Revolving Loan Agreement (account number shown above.) T0; HFC ON ACCOUNT NUMBER 71330323145440.......... ... ................s 10074.60 Initial Annual Fee ............................................................5 50.00 CASH OR CHECK TO BORROWER ................ ......................... ............ s 5.40 TOTAL ADVANCE(S) ..............................................................s 10130.00 BORROWERS: 08-26-04 RL RL Vauchher 1 11 111101 1111 11ONINEll lm8 11 Vou ¦S6432973OA97RLV9000PA1319210'*STINE ¦ ORIGINAL PA 137921 VERIFICATION Carrie A. Radcliff Recover Specialist for HOUSEHOLD FINANCE 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. Ca -a A. Radcli f .j ? W ? r' wy 7 r? rj T1 SHERIFF'S RETURN - REGULAR CASE NO: 2009-01021 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER DIS VS STINE RONALD E AMANDA COBAUGH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE STINE RONALD E was served upon the DEFENDANT , at 0020:35 HOURS, on the 23rd day of February-, 2009 at 197 SKYLINE DRIVE MECHANICSBURG, PA 17050 by handing to a true and attested copy of NOTICE COMPLAINT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 7.20 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 35.20 02/24/2009 CHROMULAK & ASSOCIATES Sworn and Subscibed to By: before me this day Deputy Sheri f of A.D. r-? r? ?-? J -' - U. ?,? ?::. ?? ..,..a ? ' t i "' ? ?, _. ?\ ?'? Household Finance consumers Discount Company Division Plaintiff, VS. PLEADING: Ronald E. Stine, Defendant, In Response: Civil N. 09-1021 TYPE OF Complaint I atempted to make smaller payments to Household Finance Consumers Discount Company and they were refused by the collections company. I am more than willing to settled the debt. I was told that I would have to pay in full in order to settle instead of making payments. At this time and with the state of the economy I am unable to pay in full. I would like to make arrangements to make payments in order to settle this debt. Thank you Ronald E. Stine 197 Skyline Drive Mechanicsburg, Pa. 17050 717-805-8272 3/24/2009 • !*_? ?r ?? i " ? ? C!T ,,, ?. (?w".. >b '!l ?i.: ; .• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. RONALD E. STINE, and AMERICHOICE FCU, Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant, Garnishee. Defendant's Address: 197 SKYLINE DR. MECHANICSBURG, PA 17050 Garnishee's Address: 20 SPORTING GREEN DR. MECHANICSBURG, PA 17050 Date: MAY 26, 2010 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 09-1021-CIVIL TERM c © '' r., ' _ , ---+ -" f- ~ _ ' -r; ~ TYPE OF PLEADING: '~ ~ ~ - ; ... ;, PRAECIPE FOR A WRIT OF ' L~;; ~ EXECUTION ~ =;~ ~' 0 :.tom FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO.42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 ~RESA 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 .~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. RONALD E. ST1NE, and AMERICHOICE FCU, TO: The Prothonotary Defendant, Garnishee. CIVIL DIVISION No. 09-1021-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION ~~~ N° ~~~~' ~ee ~ ~n Please issue a Writ of Execution in the above matter, I . directed to the Sheriff of CUMBERLAND County; 2. against RONALD E. STINE, defendant, and 14~ °.sk-ylin~ l7rlVe, Merl, , PA, i7o50 3. against AMERICHOICE FCU, garnishee, ao Sporting (~' I~Ei°h l~r, McCI~ , Qp 17050 4. and index this writ a. against RONALD E. STINE, defendant, and b. against AMERICHOICE 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 lomt, personal and business. O 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. $14,173.41 $ 536.19 $ 600.00 $14,109.60 ¢~`I•So Pnr4rry 35, d0 C8F ~8.SO rr a~.oo N I +1. oo ~, a.so I ?8 • ~0 - PD A~r1 CATHY ANN CHROMULAK, ESQ. BETH ARNOLD HOWELL, ESQ. TERESA K. FUCHS, ESQ. JENNIFER M. PALONIS, ESQ. ~a.~ D~Co 5o U. ~~ l3l O$ 2#a~+as78 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1021 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 RONALD E. STINE, 197 SKyline Drive, 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 GARNISHEE(S) as follows: AMERICHOICE FCU, 20 Sporting Green Drive, Mechanicsburg, PA 17050 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 $13,573.41 Interest $536.19 Atty's Comm Atty Paid $178.70 Plaintiff Paid Date: 5/28/10 (Seal) REQUESTING PARTY: L.L. $.50 Due Prothy $2.00 Other Costs l Dav well, Prothonotary By: Deputy Name TERESA K. FUCHS, ESQUIRE Address: CHROMULAK & ASSOCIATES, LLC 401 TECHNOLOGY DRIVE, SUITE 202 CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 205696 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~_ Sheriff ~I~~- :'r ~~ :~. ~xtr of ~"ia~~bf Trig f'`i'' `.~'`;i~,~.~~~ Jody S Smith ~~" '~~ Chief Deputy ~ ~~~, . " Richard W Stewart ~:~~-.~-~ Solicitor rlcE,r.'€~+e~, ~ ~ --, ~,~ R stir ~.~ :. ~ +.:.~E.1Nil ,~.. It c:dl r. r. ~ ~ i'~P~~r~~ ~ ~ r-~,~*ft~ .. Household Finance Consumer Discount Co. vs. Case Number Ronald E Stine 2009-1021 SHERIFF'S RETURN OF SERVICE 06/07/2010 12:30 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2010 at 1230 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ronald E. Stine, in the hands, possession, or control of the within named garnishee, Americhoice Federal Credit Union, 20 Sporting Green Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, by handing to Carrie Dehart, Members Service Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 8, 2010 to Ronald E. Stine at 197 Skyline Drive, Mechanicsburg, PA 17050. SO ANSWERS, June 08, 2010 t R ANDERSON RIFF rx c~onxlin, Deputy ;ci CountySuite Shenff. ieieosoft. Inr,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Household Finance Consumer Discount Company, Plaintiff, vs. Ronald E. Stine, Defendant, and Americhoice FCU, Garnishee. 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. CIVIL DIVISION No. 09-1021 Civil Term TYPE OF PLEADING: Praecipe to Discontinue c Against Garnishee ONLY ,ry ?F-_ TYPE OF CASE: `- :27 ' ' 5 Civil Action LID FILED ON BEHALF OF: Household Finance Consumer Discount Company COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 '-- i RESA 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 -*'8.0o PD A7N 0,113'7 89 P#,W817? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Household Finance Consumer Discount Company. Plaintiff, vs. Ronald E. Stine, and Americhoice FCU, Defendant, Garnishee. CIVIL DIVISION No. 09-1021 Civil Term PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY To the Prothonotary: Please discontinue this action against the above garnishee, Americhoice FCU, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By:'?l- 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 111- day of L<" "V 12010. Notary Public COMMONWEALTH OF PENNSYLVAKIA NotaMal Seal Heather L. Hatfield, Notary PUWk Cecil Twp., WaSMngGon Cowry My Commission Expires June 29, 2014 Member. Pennsvlvania Association of Noferfes THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, counsel for Household Finance ConsumerDiscount 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 9th day of September, 2010: Americhoice FCU 20 Sporting Green Dr. Mechanicsburg, PA 17050 Ronald E. Stine 197 Skyline Drive Mechanicsburg, PA 17050 f. 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. f WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1021 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 RONALD E. STINE, 197 SKyline Drive, 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 GARNISHEE(S) as follows: AMERICHOICE FCU, 20 Sporting Green Drive, Mechanicsburg, PA 17050 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 $13,573.41 L.L. $.50 Interest $536.19 Atty's Comm % Due Prothy $2.00 Atty Paid $178.70 Other Costs Plaintiff Paid Date: 5/28/10 Da . Bue , rotho otary (Seal) By: Deputy REQUESTING PARTY: Name TERESA K. FUCHS, ESQUIRE Address: CHROMULAK & ASSOCIATES, LLC 401 TECHNOLOGY DRIVE, SUITE 202 CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 205696 F? M- Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Na?C?titS' ?t tarm?,r?,f?t I NE PPO I NO,," :. 2911 JAM -6 AM Q. 28 ;1" UMBHW,J PSVF-, Household Finance Consumer Discount Co. I Case Number vs. Ronald E Stine 2009-1021 SHERIFF'S RETURN OF SERVICE 06/07/2010 12:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2010 at 1230 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ronald E. Stine, in the hands, possession, or control of the within named garnishee, Americhoice Federal Credit Union, 20 Sporting Green Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, by handing to Carrie Dehart, Members Service Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 8, 2010 to Ronald E. Stine at 197 Skyline Drive, Mechanicsburg, PA 17050. 01/05/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $91.62 January 05, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF Wy on R. Lan z 1 (51 d'. -n -? 1P 11( . S-6 erg ry44.ZS .?S33o ot., SHERIFF'S OFFICE OF CUMBERLAND COUNTY . »urry5ulle Shenft. Teaecse+.'f. In;:. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. RONALD E. STINE, and M&TBANK, Plaintiff's Address§: 2700 Sanders Road Prospect Heights, IL 60070 Defendant, Garnishee. Defendant's Address: 197 SKYLINE DR. MECHANICSBURG, PA 17050 Garnishee's Address: 812 1/2 WEST HIGH ST. CARLISLE, PA 17013 Date: MAY 31, 2012 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION 6BTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 09-1021 CIVIL TERM TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 ?ATHAN A. MORGAN, ESQ. PA ID NO. 202885 CHROMULAK & ASSOCIATES, L.L.C. 401 Technology Drive Suite 202 Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 09-1021 CIVIL TERM Plaintiff, vs. RONALD E. STINE, A7 3k4l`ne- br, Mechwi'u PA 17050, - r, Defendant, and 17013 rw? M & T BANK, 819, ya W 4, OarVtsle PA , Garnishee. i PRAECIPE FOR WRIT OF EXECUTION TO: The Proth;notary 1q,173-q1 X700.00 Please issue a Writ of Execution in the above matter, 1 . directed to the Sheriff of CUMBERLAND County; I l i 473 V 2. against RONALD E. STINE, defendant, and 3. against M & T BANK, garnishee, 4. and index this writ a. against RONALD E. STINE, defendant, and b. against M & T BANK, garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendant in an y accounts individual and joint, g personal and business. ".Do pD ATr'Y 35.6to CBF 5. Amount of Judgment $14,173.41 QI. loa " Additional Interest to Date $ 2,224.61 X8.50 " (Costs'Ao be added) $ aµ. A° ? oo N Less $ 2,700.00 . aH.SO Pursuant to Writ of Execution $13,698.02 g ? And Service of Wri t pa arty THIS IS AN ATTEMPT TO COLLECT A DFIBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TkAT PURPOSE. CA HY ANN CHROMUL K, ESQ. BETH ARNOLD HOWELL, ESQ. 4A as alsC! NATHAN A. MORGAN, ESQ. 6trlWA9 E 174a 170 Wr4uALot WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-1021 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 RONALD E. STINE, 197 Skyline Drive, 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 GARNISHEE(S) as follows: M&T BANK, 812 '/: W. High Street, Carlisle, PA 17013 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 $11,473.41 Interest to date -- $2,224.61 Arty's Comm % Arty Paid $304.82 Plaintiff Paid L.L. S Due Prothy $2.25 Other Costs Date: 6/4/2012 (Seal) David D. Buell, Prothonotary By: Deputy REQUESTING PARTY: Name : NATHAN A. MORGAN, ESQUIRE Address: CHROMULAK & ASSOCIATES, LLC 401 TECHNOLOGY DRIVE, SUITE 202 CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2436 Supreme Court ID No. 202885 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor QeF C.E ?F ' c-ERiFF 12 Jtqv 13 PH 1: r PEh9js YL. Household Finance Consumer Discount Co. vs. Ronald E Stine Case Number 2009-1021 SHERIFF'S RETURN OF SERVICE 06/11/2012 09:26 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2012 at 0926 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ronald E. Stine, in the hands, possession, or control of the within named garnishee, M&T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Donna Egolf, Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 12, 2012 to Ronald E. Stine, 197 Skyline Drive, Mechanicsburg, PA 17050. SO ANSWERS, June 12, 2012 RON R ANDERSON, SHERIFF //j/y2E-" W iam Cline, Deputy !c) CounrySuite Shenft. leieosoft Inc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Household Finance Consumer CIVIL DIVISION Discount Company, Plaintiff, Case No. 09-1021 Civil Term vs. , ., Fri ?- .n, r Ell Ronald E. Stine, Defendant 7 , and -- M&TBank, t Garnishee. i PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY To the Prothonotary: Please discontinue this action against the above garnishee, M & T Bank, and mark the docket accordingly. Respectfully submitted, 1i Sworn to and subscribed Before me this Z day of 2017- IL .4d Notary Pu lic CHROMULAK & ASSOCIATES, L.L.C. By: Y CATI. Y ANhCHROVMUL5 A, ESQ. BETH ARNOLD HOWELL, ESQ. NATHAN A. MORGAN, ESQ. Counsel for Plaintiff 401 Technology Drive, Suite 202 Canonsburg, PA 15317 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Heather L. Hatfield, Notary Public Cecil Twp., Washington County My Commission Expires June 29, 2014 Member. Pennsvlvenia Association of Notufes is THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. am .SOp? Q " G16r) k. k MIu7 CERTIFICATE OF SERVICE I, counsel for HoWehold Finance ConsumerDiscount 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 22nd day of June, 2012: M&TBank PO Box 844 Buffalo, NY 14240 Ronald E. Stine 197 Skyline Drive Mechanicsburg, PA 17050 r Cathy Ann Chromulak, Esq. Beth Arnold Howell, Esq. Nathan A. Morgan, Esq. Chromulak & Associates, L.L.C. 401 Technology Drive, Suite 202 Canonsburg, PA 15317 w THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r" (-14. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Wyk tr et arar�#+r I {k G T;. 41:114, ( + _ Jody S Smith Chief Deputy V. ,U T 17 € t Richard W Stewart Solicitor oFFcE OF .r 'L Household Finance Consumer Discount Co. vs. Case Number Ronald E Stine 2009-1021 SHERIFF'S RETURN OF SERVICE 06/11/2012 09:26 AM -William Cline, Deputy Sheriff,who being duly sworn according to law, states that on June 11, 2012 at 0926 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Ronald E. Stine, in the hands, possession, or control of the within named garnishee, M&T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Donna Egolf, Teller, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 12, 2012 to Ronald E. Stine, 197 Skyline Drive, Mechanicsburg, PA 17050. 10/16/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $88.81 SO ANSWERS, October 16, 2013 RONNK ANDERSON, SHERIFF a.as. �cLc e 93s"9 ici Ccunty;wie Sherit'Teleosof• ',.,,. P. � 9 18