HomeMy WebLinkAbout01-6622IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
RICHARD B. BUCHER,
Defendant.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL
60070
Defendant's Address:
37 N. Baltimore Avenue
Mt. Holly Springs, PA
17007
CIVIL DIVISION
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
MICHELLE D. SMITH, ESQ.
PA ID NO. 74800
MOLLICA & MURRAY
Firm #952
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211-1205
(412) 381-7000
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,
No.
Plaintiff,
vs.
RICHARD B. BUCHER,
Defendant.
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 - 800-990-9108
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
RICHARD B. BUCHER,
Defendant.
CIVIL DIVISION
COMPLAINT
AND NOW COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPAA~Y, by its Attorneys, Mollica & Murray, 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 situate at
2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred
to as "Plaintiff".
2. RICHARD B. BUCHER is an adult individual residing at
37 N. Baltimore Avenue, Mt. Holly Springs, PA 17007.
3. On or about August 10, 1999, Defendant entered into
a Loan Agreement with the Plaintiff, a copy of which is attached
hereto as "Exhibit A" and incorporated herein.
4. Pursuant to the 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 Agreement for failing to make
payments when due, with the last payment having been made on or
about May 31, 2001.
6. Pursuant to the terms of the 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 Thirteen Thousand Four
Hundred Forty Five and 33/100 ($13,445.33) Dollars as of October 5,
2001.
7. Numerous demands have been made upon Defendant by
Plaintiff, but Defendant has failed or refused to pay.
8. Pursuant to the Agreement, Plaintiff is entitled to
recover costs of collection and reasonable attorney's fees.
W~EREFORE, Plaintiff claims damages in the sum of
Thirteen Thousand Four Hundred Forty Five and 33/100 ($13,445.33)
Dollars, with interest thereon at the rate of 21.991% from October
5, 2001, plus court costs and attorneys' fees.
Respectfully submitted,
MOLLICA & MURRAY
By:
CAT~ ANNh~ROMULAK, ESQ.
PA ID NO. 42067
MICHELLE D. SMITH, ESQ.
PA ID NO. 74800
Attorneys for Plaintiff
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE,
LOAN REPAYMENT AND SECURITY AGREEMENT [Page I o! 2)
CREDITOR (called "We," "Us," "Our")
HOUSEHOLO FINANCE CONSUMER OISCOUNT COMPANY
25 GATEWAY DRIVE
GATEWAY SQUARE/SUITE 1DJ
MECHANICSBURG PA 17055
BORROWERS (called "You," "Your")
BUCHER. RICHARD B
SS# 209641759
37 N BALTIMORE AVE
BOILING SPRGS PA 17007
08110/88
LOAN NO: 3133°3-983189
257.52 ~7
~fAt~ pA, YmJ~NTa
318.48 ,J/.. 318.48
NONE
YOU ARE GIVING US 'A SECURITY iNTEREST IN THE REAL'EStATE LOCATED AT THE ABOVE ADDRESS,
REQUIRED INSURANCe. Ynu must obtaia insurance for term of loan covering sacurity for ~s roan as ~d~at~ by t~ wozd 'YES'
~low. ~mln~ ~s &s Loss Poy~:
Y ES ~xe end Q~nd~ covor~'i~a~ ~*r~t e~No s~urit~.
Physical damage insurn~ ~ o~ ~operty mnrk~ "[nsured" ~r '~Ufity' a~ve.
You may obte~ any r~u~ i~ran~ from anyoae you ch~se.
NOTICE: THE FOLLOW~[NG PAGE CONTAINS ADDITIONAL CONTRACT TERMS.
0~J-25'97 LIs PA C.E~
MORT.
~tGI~L
I
PA065911
[ LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 2} .
PAYMENT. In return[ for your loan described below, you sha 1 pay us the Amount Financed including the Fee {all shown
on page one) plus ln'terest, in monthly payments, including any final Balloon Payment, as stated on page one. You may
pay more at any tin'ir. You will pay at our business address or other address given you. If more than one Borrower is
named on page one, iw.e may ~nforce this Agreement against all, or any, Borrowers, but not in.a combined amount greater
than the amount oWe, d. Each payment will be first applied to F nance Charges at the Contract Rate shown on page one for
the actual time unpaid and the remainder to your unpa{d Principal. For purposes o.f computing Einance Charges, a month
shall be considered s4y period of 30 consecutive days.
DATE ON WHICH .FINANCE CHARGE BEGINS. If you do not cancel this loan according to your "Notice of Right to
Rescind," the date off which Finance Charge begins, payment date, and effective date of optional insurance purchased
connection with this~i°an are postponed by thc number of days from this Agreement's date 'co date you r~eive this loan,
PAY-OUTS. You ag!er to pay-outs of Amount Financed as shown on thc Truth In Lending disclosure form. Iff pay-ours
change because loan c, losing is delayed, (a) you will pay additional amounts duc at closing, or (b) y0t~r cash or check will be
reduced to cover additional pay-outs.
PREPAYMENT. Yo~ may prepay any or all of your loan at any time. If you tully pay before thb final payment'due date,
· thc amount you owe ~ill he re,:lur~l by unearned credit insurance charges.
BAD CHECK CHARGE. We will charge you a handling fee of $20 if any payment check is returned because you had no
account or for msufhcient funds.
DEFAULT. Subject In applicable law and the mortgage on your re~l create ~uring this loan, if you don't pay on time or
fail to k~ep required insurance in force, or if you sell or transfer all or any part of that real estate or any interest therein
without our consent, ~1 your payments may become due at once. We will notify you of your Hght to correct such default
before we enforce the real estate mortgage. We may sue you for thc total amount yo6 owe, and you will also pay our
reasonable attorney fees (ff the attorney ts not our salaried employee), court costs, and fees incurred to collect this loan
I '
EXCHANGE OF INFORMATION. You understand that from time to time we may ret, dye credit information
concerning you froml othem, 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 informatio,'n, with any of our affiliated corporations, subsidiaries or other third parties. The uses of this
information may include an inquiry to d~termine if you qualify for additional offers of credit. You also authorize us to
share any mformat~o9 regarding your Account with any of our affiliated corporations, subsidiaries ut other third parties.
After September 29, 1997, you may prohibit tho 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 8602, Elmhurst, IL 60126.
If 'GU fail to fulfill ]the terms of our ~,Tedit obli ation a ne t'v rt
~. .. . y g , ga ~ e repo renecting on your crenit record ma-~ he
submttted to a CredLt Reporting Agency. You agre~ that the Department of Motor Vehicles (or your ~ate's equivalent
of such department) ~nay release your residence address to us, should it become nec _,~t~__ry to locate you. You agree :hat
our supervisory personnel may li~ten to .telephone calls between you and our reptesen~tives in order to evaluate the
quality of our service to you.
YOU HAVE RECEIVED A COMPLETED COPY
OF THIS AGREEMENT AND THE TRUTH-IN-LENDING
DISCLOSURES.
ORIGINAL
09-29-97 LIS PA C.E.
1ST MORT.
4WERS:
Iillllrmlllllllllllllllil lli llflllllllllilll
(SEAL)
(SEAL)
(,SEAL)
PAOB691Z
I
VERIFICATION
Merrilee Mastrangelo, Recovery Specialist for
HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANy, a Household International 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 foregoing Complaint are true and correct
to the best of her knowledge, infoi-Jnation and belief.
ITHIS IS AN ATfEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
SHERIFF'S RETURN -
CASE NO: 2001-06622 P
COMMONWEALTH OF pENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
BUCHER RICHARD B
REGULAR
CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPI~AINT & NOTICE was served upon
BUCHER RICHARD B the
DEPENDANT , at 1244:00 HOURS,
at 37 N BALTIMORE AVE
MT HOLLY SPRINGS, PA 17065
RICHARD B. BUCHER
a true and attested copy of COMPLAINT
on the 30th day of November , 2001
by handing to
& NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.90
Affidavit .00
Surcharge 10.00
.00
31.90
Sworn and Subscribed to before
me this 7-- day of
~ ~/ A.D.
,t~rothonotary '
So Answers:
R. Thomas Kline
MOLLICA &
By:
Z/v Depu%!/ Sheriff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
vs.
RICHARD B.
Plaintiff,
BUCHER,
Defendant.
CIVIL DIVISION
No. 01-622 Civil Term
TYPE OF PLEADING:
Praecipe for
Default Judgment
TYPE OF CASE:
CIVIL ACTION
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL
60070
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MICHELLE D. SMITH, ESQ.
PA ID NO. 74800
Defendant's address:
37 North Baltimore Avenue
Mt. Holly Springs, PA 17007
MOLLICA & MURRAY
FIRM #952
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211-1205
(412) 381-7000
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
TO: PROTHONOTARY
Please enter judgment by default against the
defendant, RICHARD B. BUCHER, for failure to file
follows:
within-named
an Answer as
Amount claimed in Complaint:
$13,445.33
Interest from 10/6/01 thru 1/03/02:
606.99
Costs of Collection thru 1/03/02:
554.50
TOTAL $14,606.82
With interest accruing on the total balance of $14,606.82 at the
rate of 6% per annum, together with additional costs of suit.
CATH~ 'A~' CHROMULAK, ESQUIRE
MICHELLE D. SMITH, ESQUIRE
Attorneys for Plaintiff
AFFIDAVIT OF NON-MILITARY SERVICE
AND CERTIFICATION OF MAILING OF NOTICE OF
INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ALLEGHENY
SS:
Before me, the undersigned authority, a Notary Public in and
for said County and State, personally appeared MICHELLE D. SMITH,
ESQUIRE, attorney for and authorized representative of plaintiff
who, being duly sworn according to law, deposes and says that the
defendant is not in the military service of the United States of
America to the best of her knowledge, information and belief and
certifies that the Notice of Intent to take Default Judgment was
mailed to defendant on December 21, 2001 by certificate of
mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the
attached copy.
CATHY ANN CHROMULAK, ESQ.
MICHELLE D. SMITH, ESQ.
Sworn to and subs, gj~ibed before me
this 7~ . day of~ 2002.
Notarial Seal
Yvonne, Gardner Jones. Notary Public
Pittsburgh, Alle~lhen¥ County
My Commission Expires .Jan. 29, 2005
Merntmr, PenssylvaniaAssociation olNotari ~I'HI$ 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.
RICHARD B.
BUCHER,
Defendant.
CIVIL DIVISION
No. 01~2~-CIVIL
TO:
RICHARD B. BUCHER
37 N. Baltimore Avenue
Mt. Holly Springs, PA
17001
DATE OF NOTICE: December 21, 2001
IMpORTA/qT 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; 800-990-9108
By:
CAT[{Y 'AI~ CHROMULAK, ESQ.
MICHELLE D. SMITH, ESQ.
Attorneys for Plaintiff
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
THAT PURPOSE.
OBTAINED WILL BE USED FOR
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2001-06622 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER DIS
VS
BUCHER RICHARD B
And now DOUGLAS DONSEN ,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:29 Hours, on the 21st day of February , 2002, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
BUCHER RICHARD B , in the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
WINI QUESENBERRY (BRANCH MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within COMPLAINT & NOTICE
true
and made
the contents there of known to Her
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
So an :
R. Thomas Kline
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
this ~7~ day of ~.~
/') Pro t'h-o~o~ y ~
By
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
vs.
RICHARD B.
Plaintiff,
BUCHER,
Defendant,
Garnishee.
and
COMMERCE BANK,
CIVIL DIVISION
NO. 01-6622
TYPE OF PLEADING:
Praecipe to Settle and
Discontinue Against Garnishee
ONLY
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL
60070
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MICHELLE D. SMITH, ESQ.
PA ID NO. 74800
MOLLICA & MURRAY
Firm #952
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211-1205
(412) 381-7000
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,
HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
No. 01-6622
Plaintiff,
PENNSYLVANIA
vs.
RICHARD B. BUCHER,
Defendant,
and
COMMERCE BANK,
Garnishee.
PRAECIPE TO SETTLE AND DISCONTINUE AGAINST GARNISHEE ONLY
TO PROTHONOTARY:
Please settle and discontinue this action against the above
garnishee, COMMERCE BANK and mark the docket accordingly.
By:
Sworn to and subsGribed
befor9 me. this /~ day
,o.,F 2002.
~otary Public
Respectfully submitted,
MOLLICA & MURRAY
CATHY ANN CHROMULAK, ESQ.
MICHELLE D. SMITH, ESQ.
Attorneys for Plaintiff
1305 Trimont Plaza
Suite 4504
Pittsburgh, PA 15211-1205
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
C~RTIFICATE OF SERVICE
I, Michelle D. Smith, Esquire, counsel for HOUSEHOLD FINANCE
CONSUMER DISCOUNT COMPANY hereby certify that a true and correct
copy of the foregoing Praecipe to Settle and Discontinue Against
Garnishee Only was served upon the following by First Class Mail,
postage prepaid on this 13th day of MARCH, 2002:
COMMERCE BANK
65 Ashland Avenue
Carlisle, PA 17013
RICHARD B. BUCHER
37 North Baltimore Avenue
Mt. Holly Springs, PA 17007
Mich~lle D. Smit , sq.
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
VS.
Plaintiff,
RICHARD B. BUCHER,
Defendant.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
CIVIL DIVISION
No. 6622 Civil Term
TYPE OF PLEADING:
Praecipe to Satisfy
Judgment
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
MICHELLE D. SMITH, ESQ.
PA ID NO. 74800
MOLLICA & MURRAY
Firm #952
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211-1205
(412) 381-7000
ITHIS 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.
CIVIL DIVISION
No. 6622 Civil Term
RICHARD B. BUCHER,
Defendant.
PRAECIPE TO SATISFY JUDGMENT
TO: PROTHONOTARY
Please satisfy the judgment against RICHARD B. BUCHER, at No. 6622 Civil
Ten,, and mark the docket accordingly.
Respectfully submitted,
MOLLICA & MURRAY
By:
Sworn to and Subscribed to
before me this /D day of
~002.
v _ No~/l~b.l~c -
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MICHELLE D. SMITH, ESQ.
PA ID NO. 74800
Attorneys for Plaintiff
450 Trimont Plaza
1305 Grandview Avenue
Pittsburgh, PA 15211
ITHIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
CERTIFICATE OF SERVICE
I, Michelle D. Smith, Esquire, counsel for Plaimiff, HOUSEHOLD FINANCE
CONSUMER DISCOUNT COMPANY hereby certify that a true and correct copy of the
foregoing Praecipe to Satisfy Judgment was served upon the following by United States First
Class Mail, postage prepaid on this ./,9/t-'day of September, 2002:
RICHARD B. BUCHER
37 North Baltimore Avenue
Mt. Holly Springs, PA 17007
Mich611e D. Smith, Esq.
THIS IS AN ATTEMPT TO COLLECT
A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR
THAT PURPOSE.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 01-6622 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONS. DISC. CO
PLANTIFF(S)
From RICHARD B. BUCHER
(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 COMMERCE BANK, 65 ASHLAND AVE., CARLISLE PA 17013.
GARNISHEE(S) as follows:
ANY PROPERTY OF DEFENDANT 1N THE NAME OF GARNISHEE ANT) KINDLY SERVE
INTERROGATORIES..
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined
fi.om 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 $14,606.82 L.L. $.50
Interest $97.20 Due Prothy $1.00
Atty's Corem % Other Costs $.50 STATE TAX
Atty Paid $103.90
Plaintiff Paid
Date: FEBRUARY 19, 2002
REQUESTING PARTY:
Name MICHELLE D. SMIITH, ESQ.
Address: 1305 GRANDVIEW AVE.
45- TRIMONT PLAZA
PITTSBURGH PA 15211
Attorney for: PLAINTIFF
Telephone: (412) 381 7000
Supreme Court ID No. 74800/
CURTIS R. LONG
Prothonotary, Civil Division
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Docketing 18.00
Poundage 1.43
Advertising
Law Library .50
Prothonotary 1.00
Mileage 3.45
Misc.
Surcharge 20.00
Levy 20.00
Post Pone Sale
Garnishee 9.00
73.38
Advance Costs: 150.00
SheriWs Costs: 73.38
76.62
Refunded to Arty on 10 / 11/02
Sworn and Subscribed to before me
this )$'* day of_(~e~__
2002 A.D. (~.... ~.. ~t,~-~,~t~7,-
So Answers;
R. Thomas Kline, Sheriff