HomeMy WebLinkAbout09-3048IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Beneficial Consumer Discount Company,
Plaintiff,
Vs.
Karla M. Forbes and Kip P. Forbes,
CIVIL DIVISION
No. 04 -30Y8
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
Beneficial Consumer Discount Company,
Plaintiff,
VS.
Karla M. Forbes and Kip P. Forbes,
Defendants.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendants' Address:
5240 Terrace Road
Mechanicsburg, PA 17050
THIS 13 AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CIVIL DIVISION
No.
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
4`h 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.
Karla M. Forbes and Kip P. Forbes,
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. Karla M. Forbes and Kip P. Forbes are adult individuals residing at 5240 Terrace
Road, Mechanicsburg, PA 17050, hereinafter referred to as "Defendants."
3. On or about June 1, 2005, the 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 13 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 31, 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 Sixteen Thousand Eight Hundred Fifteen and 63/100 Dollars
($16,815.63) as of March 26, 2009.
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 Sixteen Thousand Eight Hundred
Fifteen and 63/100 Dollars ($16,815.63), with interest thereon at the rate of 24% from March 27, 2009,
plus court costs and attorney's fees.
Respectfully submitted,
Chromulak & Associates, LLC
By: 156?? ftvya
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.
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 1 of 4)
Y
LENDER (called "We", "Us", "Our")
BENEFICIAL CONSUMER DISCOUNT COMPANY
4910 CARLISLE PIKE
SUITE 104-HAMPDEN CENTER
MECHANICSBURG PA 17050
BORROWERS (called "You", "Your") LOAN NO: 711714-20-513728
FORBES, KARLA M
SS# 9374
FORBES, KIP P
SS# 9132
5240 TERRACE RD
MECHANICSBURG PA 17050
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 damage 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 AODITIONA' INFORMATION REGARDING YOUR RIGHTS TO DISPUTE
BILLING ERRORS. 1 low IS1 PA056361
F NRE 00
F NRE "FO4TAIBC3K83RLAlOGOPAO56361 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 must BF-wntten 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,
mtnlstrative rges (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' few, 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'Tixk"s" o y 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 Lane 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
greater of $25 or the Payment mount (as described below) plus any Administrative Charges and credit insurance charges,
rounded to the nearest $1; or (2) the Finance Charges due for the billing cycle plus any Administrative 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 Payment Amount
through Account Balance
over 1.33% through 1.45% 1.55% of Account Balance
over 1.45% through 1.57% 1.67% of Account Balance
over 1.57% through 1.70% 1.80% of Account Balance
over 1.70% through 1.83% 1.93% of Account Balance
over 1.83% through 1.95% 2.00% of Account Balance
over 1.95% 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 calculated 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 nn 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 IMPORTANr INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING
ERRORS. nn ??II
03NRE-00 I ?? YI?INa? 1 l1110110 1®r l® PA056362
MF047AIBC3K93RLA9000PA05536Z0""FORGES " ORIGIN4L
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 re tt 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
change the terms o this Agreement, me u ing 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 now and outstanding balances unless prohibited by applicable law.
Default and Cancellation of Agreement: We have the right to require you to pay your entire balance plus all other
ace ui unpal charges immediately an or to caned 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 (it attorney is not our salaried employee), and other
collection costs related to the default, if not prohibited by applicable law.
I. 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 information 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 gent you the
first bill on which the error or problem appeared. You can telephone bender, but doing so will not preserve your rights.
NOTICE: SEE THE FOLLOWING PAGE FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING
ERRORS.
03-01-00
F
F NRE
NRE 111 NO IIIME11INME IN 1111 PA056363
mF047AISC3K93RLA9000PAOSS363ONKFORBES K ORIGINAL
PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 4 of 4)
In your letter, give Lender the following information:
• Your name and account number.
e 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. 's
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 you to. Lender must tell anyone Lender reports you to that the matter has been settled between us
when it finally is.
If Lender doesn't follow these rules, Lender can't collect the first $50 of the questioned amount, even if your bill was
correct
Alternative Dispute Resolution and Other Riders: The terms of the Arbitration Agreement and any other Ridert
signed 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 scount Company Act, Chapter 7, Sections 6201 through 6221, Purdon's Pennsylvania Statutes Annotated,
particularly Section 6217.1.
Before signing this Agreement, you have read and received this Agreement and the Federal Truth-In-Lending
disclosures contained in it.
You, the customer(s) signing below, agree to observe the terms and conditions of this Agreement.
This Agreement is entered under the applicable provisions of Federal law and the Pennsylvania Consumer
Discount Company Act.
kOiA - N. . L (SEAL)
mer ignature
" ` - y J
Date: CP
/o/v (SEAL)
uusm signature
Date:
n
(SEAL) (SEAL)
t.
03-01-00
RL F NRE
"F047A1BC3K93RLA9000PA0SS3640""FORMES "
PAOSS364:
ORIOINI1.
LOAN CLOSING STATEMENT (Page 1 of 1)
REVOLVING LOAN VOUCHER
CREDITOR
BENEFICIAL CONSUMER DISCOUNT COMPANY
4910 CARLISLE PIKE
SUITE 104-HAMPOEN CENTER
MECHANICSBURG PA 17050
BORROWERS
FORBES, KARLA M
FORBES, KIP P
5240 TERRACE RD
MECHANICSBURG PA 17050
LOAN NO: 711714-20-513726
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.)
TO: KARLA M FORBES(FIMC,HOME & AUTO SECURITY) ............................ ,.... f 599.95
Initial Annual Fee ............................................................5 50.00
CASH OR CHECK TO BORROWER .....................................................5 4000.05
TOTAL ADVANCE M ..............................................................! 4650.00
BO ROWERS:
t
RL Voucher
"F047A1BC3K93RLVIOOOPA137921O"KF0RBES K ORIGINAL PA137921
VERIFICATION
Carrie A. Radcliff Recover Specialist for
Deposes and says subject to the penalties of 18 Pa C.S.'Section 4944 relating to unswom
falsification to authorities, that the facts set forth in the forgoing Complaint are true and
correct to the best of her knowledge, information and belief.
S
Q
2699 KY 13 PH 1: 20
l y
-9 '?'8. s'd i??L Ably
CK-1 tissue
R-4- .-.2.567 3
Sheriffs Office of Cumberland County
R Thomas Kline gotr of cnatbrrr? Edward L Schorpp
Sheri Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy OFFICE OF THE S"@RIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
05/14/2009 07:20 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 14,
2009 at 1920 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Karla M. Forbes, by making known unto Karla M. Forbes personally, at 5240 Terrace
Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055 its contents and at the same time
handing to her personally the said true and correct copy of the same.
05/14/2009 07:20 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 14,
2009 at 1920 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Kip P. Forbes, by making known unto Karla M. Forbes, wife of defendant, at 5240
Terrace Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055 its contents and at the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $54.80
SO ANS RS
May 15, 2009
2009-3048
Beneficial v Karla Forbes
R THOMAS KLINE, ERIFF
De ty Sheriff
Lam ru
,
w
4- ?5
t l
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENN YLVANIA
BENEFICIAL CONSUMER DISCOUNT CIVIL DIVISION
COMPANY,
No. 09-3048 CNIL TERM
Plaintiff,
TYPE OF PLEADING:
vs.
Praecipe for Default Judgment
KARLA M. FORBES
and KIP P. FORBES,
Defendants.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendants' Address:
5240 TERRACE ~ZOAD
MECHANICSBURG, PA 17050
Dated: JUNE 16, 2009
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
BENEFICIAL CONSUMER D
COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK,
PA ID N0.42067
BETH ARNOLD HOWELL, ES
P~1 ID NO. 203606
ERESA K. FUCHS, ESQUIRE
PA ID NO. 205696
JENNIFER M. PALONIS, ESQI
PA ID NO. 205703
OUNT
CHROMULAK & ASSOCIATEq
401 Technology Drive
Suite 202
Canonsburg, Pennsylvania 15317
(724) 916-2400
L.L.C.
THIS IS AN ATTI$MPT TO
COLLECT A DE T AND
ANY INFORM TION
OBTAINED WILL E USED
FOR THAT PURPOSE.
TO: PROTHONOTARY
Please enter judgment by default against the within-named defendants,
FORBES and HIP P. FORBES, for failure to file an Answer as follows:
Amount Claimed in Complaint: $16,815.63
Less Payments Received: 1 350.00
Amount Owed: $15,465.63
Interest from MARCH 27, 2009 through JUNE 16, 2009: $800.54
Costs of Collection through JUNE 16, 2009: $547.30 ~
TOTAL $16,813.47
With interest accruing on the total balance of $16,813.47 at the rate of 6% per
with additional costs of suit.
CATHY ANN CHROMULAK, ESQUIRE
BETH ARNOLD HOWELL, ESQUIRE
TERESA K. FUCHS, ESQUIRE
JENNIFER M. PALONIS, 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 WASHINGTON
SS:
M.
b~~
together
Before me, the undersigned authority, a Notary Public in and for said Count;
personally appeared, ~- 1<. ~Gtf~ ,ESQUIRE, attorn~
authorized representative of plaintiff who, being duly sworn according to law, depos
that the defendants are not in the military service of the United States of America to
her knowledge, information and belief and certifies that the Notice of Intent to t~
Judgment was mailed to defendants on JUNE 4, 2009 by certificate of mailing in
with Pa.R.C.P. 237.1, as evidenced by the attached copy.
CATHY ANN CHROMULAK, ]
BETH ARNOLD HOWELL, ES
~T'ERESA K. FUCHS, ESQUIItE
JENNIFER M. PALONIS, ESQt
Sworn to and subscribed before me
This_ day of ~A~ , 2009.
~ I.-
Notary Public '
C3iy~IMfjNW€~F4irTV~•.)F F?~NN~YL'vAvl,~
~ ~ #Vo#arial5eal
rather L. 4 ;wield, PJotary Public
~ecif'fwp., VUashin~ton County
''~' ~^on'xnlssic;-~ E~ires pure ~, 2010 I
and State,
,~ for and
and says
he best of
:e Default
THIS IS AN ATT MPT TO
COLLECT A DE T AND
ANY INFORM TION
OBTAINED WILL BE USED
FOR THAT PU POSE.
P~~717J.^si, D~G71 S'~V?^'~ ... ...,C7:7 Ctu.. :.f NO...i s.:.
~tl
J<<
,`~,,,
c°~~e~s
~a ~
~~~~ ~
Q ` o~`c~
® ~
•,~
o°~
~\'~~o`~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS~I,VANIA
BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIV
Plaintiff,
Vs. No. 09-3048
KARLA M. FORBES and
KIP P. FORBES,
Defendants.
TO: KIP P. FORBES
5240 TERRACE ROAD
MECHANICSBURG, PA 17050
DATE OF NOTICE: JUNE 4, 2009
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS ~
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHO
THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LA
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE
OUT WHERE YOU CAN GET LEGAL HELP.
TERM
T,HE
)TICE, A
VD YOU
~D TAKE
YER OR
TO FIND
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717/249-3166
By:
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CATHY ANN CHROMULAK, E~
BETH ARNOLD HOWELL, ESQ.
TERESA K. FUCHS, ESQ.
JENNIFER M. PALONIS, ESQ.
Attorneys for Plaintiff
401 Technology Drive, Suite 202
Canonsburg, PA 15317
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DN
Plaintiff,
Vs. No. 09-3048
KARLA M. FORBES and
KIP P. FORBES,
Defendants.
TO: KARLA M. FORBES
5240 TERRACE ROAD
MECHANICSBURG, PA 17050
L DATE OF NOTICE: JUNE 4, 2009
IMPORTANT NOTICE
VANIA
TERM
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING ~'I-~ .T{HE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS OTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHO LD TAKE
THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LA R 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
By:
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
CATHY ANN CHROMULAK, ES~
BETH ARNOLD HOWELL, ESQ,
TERESA K. FUCHS, ESQ.
JENNIFER M. PALONIS, ESQ. ,~
Attorneys for Plaintiff
401 Technology Drive, Suite 202
Canonsburg, PA 15317
1t....1.~-'t,f
~`~ ~ ~
~~,~~~~
. ( 1.
:;: ,.,
~h
~~
v
a
e
YLr
~~~
R
U
a
a
W
H
3
~ a
Q
V1 ~
~ ~
°~
h~
O
x
U
c ~ v i i~
~ ~
c
a
ory
. m ~ N t~ p
c
~ C ~ 'tea a
N o m
v
G
G
yl
~~~ ~ FFem~..~.~ ~ d
~ l~~'d' N ~
._ ;C
`lW ~ m ~ IO
~~- . ~.n~
^~ 8m E me
~n.a ~~
f
t
~
.
_
~
®
CLb~
~cm oN
~~ ~
O J _ ° ~ ~
a ~~ D
~
'.C(fVCS N o ¢
ooh t
~ -m
~ is
~E~. c
~ 0
d
~ m
~
~'
vE ~
~ ~
e1 ~ a m ~ ~.- m
C ~ •- N
~ ri/ N
m W
r
• ~
,
C
C d ~ ~ (A O
f
c
~
y
/ /
%
~
~ ~ C ~ },~ Ol
~~
.:
~
/
~
'''f`PY1 If~
i
~
/ f' U
' l~ Qy
a ~ E ~ " N
E n~ o ~
o ~g
C
3 Q p d
~ ~,
~
m m
o. _E ~=
~,~~ E'm
~
c ~ _ ~
°' o E ~
4 '
.,
a
m ;.
W
.O C j
N ~ M
~ h ny
n m 0 ,V y .•
~ ~ ~ ~ 'D
~ ~ > m d _
-' ~1`~
a~
~ ~ o~ ~~~~~~Q
O.
n. t7 ~ a ¢ ~ ~ o +n S m ~
~
^. U7 o r~
~ N ~
o y UdU ? Vi •
N
N
U ,! C~
'v L
C c~ m
-~ ...
.UCm~~
c~ a D ^ AU
_ v,Q ~q~~
~ •.__ ~ ~n
~
d~
~~
~
m~
a y ,
i'c-o. EaEo
._ a ~
•U L
~ 16 U-
.
m
U V
m
c d a ~
3 rL 2 ~ y
~
p C
L N
D
l
'~
^ ~0 a m
y
E a
i
o
D ,o ~ '-
N
T6~~ y
m n.. ~._
W ~ C
O
~
O
~(1 N~
M ~
F
U¢ C~ U
~
~
~
~
~ Z
m
C~~~ .~ ~ Q ~ ~ ~
Q ~ '.1.. CL
.'~.' ~
v c. Mo C7 C7 U ~
O ~ 00 a ~ ~ `Z-
0. Ox. ¢ m ~ ^
~ ~
U 4
-~ a. U U
z
~ `m
a z z ~
m a O U U 3 0
a ~,
a
~
~
~ ~
a~
~
~ ~ ~ w ~ C~ Ci ~
~ ~
a a UcG
H W
z O
x w0
~~ >"U'
wx h
~
P wF" W ¢
~ O
~
N
,
~ o
N
E
,~
~ w
Q
>
C
W U
~U
,~,
.~
.
x
p,
~.J
h
~
C7 z ~ z ~ ~
' ~~ Zz
q~ O~
w
w ~
w
Q wE-.
a0 pm
E~ '~.
~m
mow
rn
~ o E
•
G -
.~E w v~ z ,-'
v~
~
p
' .
~
~~ m
~
c
L
O ~ a~ ~ ~~ F
-
Z
!
~ ~j ~
' ~
'
~ ~ V
o V
o No
V A V
z ~ U V
Q Z ~. ~
N ~ _
~ v
O ~ m
E N
~s
z~
m
r
N
~
~
~
~
~
~
~ O r N (~ `V' Ln ~ ~
es
J
r r r r r r F
-
m
O
d
.~
d
a
H
a
'a
w
d
Q
E
0
U
d
M
7
LL
R
7
Ll.
ODD
c~
E
a
FILE- ~'?~,.=l;.~E
~ I~ ~F~TI~~', ~T~tRY
2009 J~iP~ 26 PC 1 ~ ~ 2
~c~ 9i~~~1~'~'~~~:~
~ ~F. 00 PQ Al't1/
ck`a` $y q a
fZ-T ~ :~o'Z 1,~L'1 ~
~ '4teJ2, ~~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BENEFICIAL CONSUMER DISCOUNT CIVIL DIVISION
COMPANY,
Plaintiff,
No. 09-3048 CIVIL TERM
vs.
KARLA M. FORBES
and KII' P. FORBES,
Defendants.
c
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: KARLA M. FORBES
5240 TERRACE ROAD
MECHANICSBURG, PA 17050
(X) Defendant
You are hgreby notified that an Order, Decree or Judgment was entered in the
captioned;proceeding on _~~
() A copy of the Order or Decree is enclosed, or
(X) The judgment is as follows: $16,813.47 plus interest at the rate ~if 6% per
annum and additional costs of suit. II
i i ~..c,~.cx-c ,x
--T-r
~ ~' A'~aFhono$a.rc,f
THIS IS AN ATTEMPT TO
COLLECT DEBT AND
s ANY INF RMATION
OBTAINED ILL BE USED
FOR THA PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
BENEFICIAL CONSUMER DISCOUNT
COMPANY,
Plaintiff,
vs.
KARLA M. FORMES
and KIP P. FORMES,
Defendants.
CIVIL DIVISION
No. 09-3048 CNIL TERM
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: HIP P. FORBES
5240 TERRACE ROAD
MECHANICSBURG, PA 17050
(X) Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the
captioned proceeding on ~ar~og
() A copy of the Order or Decree is enclosed, or
(X) The judgment is as follows: 16 813.47 plus interest at the rate
annum and additional costs of suit.
'~ p~~,~o~ ~ ~~
VANIA
6% per
THIS IS AN ATTEMPT TO
COLLECT DEBT AND
ANY INF RMATION
OBTAINED ILL BE USED
FOR THA PURPOSE.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
~~},t;,, at :rirr~~i~,~r~~
,_,., -
=~~ .
_ _
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
c~~-a:e=_. _.. ;..~~:~~~
,y~ .,; ~ ,_ ..,
ti' ~i°; ~ F~~ ~~ i i
Beneficial Consumer Discount Company
Case Number
vs.
Karla M. Forbes 2009-3048
SHERIFF'S RETURN OF SERVICE
11/12/2009 09:11 AM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on
November 12, 2009 at 0911 hours, attached as herein commanded all goods, chattels, rights, debts,
credits, and monies of the within named defendant, to wit: Karla M. Forbes and Kip P. Forbes, in the
hands, possession, or control of the within named garnishee, Wachovia Bank, 604 East High Street,
Carlisle, Cumberland County, Pennsylvania 17013, by handing to Jill Manley, Manager, 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 November 13, 2009 to Karla M. Forbes at
5240 Terrace Road, Mechanicsburg, PA 17050 and Kip P. Forbes, 5240 Terrace Road, Mechanicsburg,
PA 17050.
11/12/2009 09:47 AM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on
November 12, 2009 at 0947 hours, attached as herein commanded all goods, chattels, rights, debts,
credits, and monies of the within named defendant, to wit: Karla M. Forbes and Kip P. Forbes, in the
hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle,
Cumberland County, Pennsylvania 17013, by handing to Kristin Long, Assistant Manager, 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 November 13, 2009 to Karla M. Forbes at
5240 Terrace Road, Mechanicsburg, PA 17050 and Kip P. Forbes, 5240 Terrace Road, Mechanicsburg,
PA 17050.
So Answers, ,.-~
f~..,..
",..~-
R. Thomas Kline, Sheriff
B
eputy Shy iff
(rj CaunVSuit~ ahenff. Teieosofl~. h,c_