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Home My WebLink About04-2627 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL DIVISION vs. No" 04 - ;;J'-';.. 7 C0J..j ~'tItrt RICHARD SANCHEZ SR. and BRENDA SANCHEZ TYPE OF PLEADING: Complaint Defendants. TYPE OF CASE: Civil Action Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY Defendant's Address: 60 W. MAIN STREET NEW KINGSTOWN, P A 17072 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 4th Floor Canonsburg,PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. RICHARD SANCHEZ SR. BRENDA SANCHEZ 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 OR 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTATNED WILL BE USED FOR THAT PURPOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL DIVISION No. 04-~(,-;'7 CI~ll'T~ vs. RICHARD SANCHEZ SR. and BRENDA SANCHEZ, 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. RICHARD SANCHEZ SR, and BRENDA SANCHEZ are adult individuals residing at 60 W. MAIN STREET, NEW KINGSTOWN, P A 17072. 3, On or about MARCH 27, 1995, Defendants entered into a written Loan Agreement with the Plaintiff, as evidenced by the Affidavit of Lost Note attached hereto as "Exhibit A" and incorporated herein, 4. Pursuant to the Loan Agreement with the Defendants, Plaintiff advanced funds to the Defendants, THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5. Defendants are in default under the terms and conditions of the aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about JANUARY 5, 2004. 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 FOUR THOUSAND, FIVE HUNDRED SIXTY-NINE 27/100 ($4,569,27) DOLLARS as of APRIL 23, 2004. 7. Numerous demands have been made upon the Defendants by Plaintiff, but the Defendants have failed or refused to pay. 8, Pursuant to the Loan Agreement, Plaintiff is entitled to recover costs of collection and reasonable attorney's fees. WHEREFORE, Plaintiff claims damages in the sum of FOUR THOUSAND, FIVE HUNDRED SIXTY-NINE 27/100 ($4,569.27) DOLLARS, with interest thereon at the rate of 22% from APRIL 23, 2004, plus court costs and attorney's fees. Respectfully submitted, ChromuIak & Associates, LLC BY/~J- CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. STATE OF PENNSYLVANIA IN THE DISTRICT COURT FOR THE JUDICIAL DISTRICT BENEFICIAL CONSl~ER DISCOUNT COMPANY Plaintiff vs. Case No. : Defendant(s) RICHARD SANCHEZ JR AND BRENDA SANCHEZ 711715 26 118008 AFFIDAVIT OF LOST/DESTROYED INSTRUMENT JUAN GAMBOA, being sworn deposes and says: 1. That he/she is the Legal Specialist at BENEFICIAL CONSUMER DISCOUNT COMPANY and makes this Affidavit on their behalf. 2. That this Affidavit is made on informati on and belief of the affiant after thorough review of all records of BENEFICIAL CONSUMER DISCOUNT COMPANY pertinent to the Defendant's account. 3. That the original contract in this matter has been destroyed or lost. 4. That if originals or will be submitted to the Court duplicates are discovered, for cancellation. J---IcjJ /1 >,(~~~ /" /'" they Subscrib~d and swor~~ before me on this &,I--day of ~I?.x(~, 2004. t~._~ Notary Public - KHUDSIA A HUSAIN l : OFFICIAL SEAL I : IOlUlIS/A A IfUIArH : NO~~~V PUIIUC, STATE 01' II.UNoIs '- M'."("":'-I!xpI.wfj.l4-~ 1 State of ILLINOIS County of DUPAGE My commission expires on: MAY 14, 2005 . EXHIBIT I "A" .. VERIFICATION Veronica Bradford, Recovery Specialist for BENEFICIAL CONSlfrlliR DISCOUNT C01~ANY, A HOUSEHOLD INTERNATIONAL COl1PANY 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. ~~ Veronica Bradford /::J \-:I ~ il\~ ~ 8 f~ ~ ~.,<-., ....... tI) N o ~ .......( p ._,-~ ...., C~~ ;;. r:::J 8 c_ c:: ~..." "'-. o 'TI ::;J 6,:0 ~ -tJ "1 ~!)0 (~ . :7J~:' :. ~l~ C~) ...,., .: .c', r"-..> ITf (f': \.CI COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY CIVIL DIVISION No. 04-2627 Plaintiff, TYPE OF F'LEADING: vs, Acceptance of Service RICHARD SANCHEZ, SR" AND BRENDA SANCHEZ, TYPE OF CASE: Defendants, Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ill NO. 42067 SCOTT E. eRA WFORD, ESQ. PA ill NO. 89570 CHROMULAK & ASSOCIATES, LLC Defendant's Address: 60 W. MAIN STREET NEW KINGSTOWN P A 17072 375 SouthpoJinte Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 '-HIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-2627 Plaintiff, vs" RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ, Defendants" ACCEPTANCE OF SERVICE We, RICHARD SANCHEZ, SR, AND BRENDA SANCHE the Complaint on behalf of ourselves" Date: (0\ \ '\\ C)\ ~ \ Richard Sanchez, Sr. 60 W. Main Street New Kingstown, P A 17072 ~ Bren 60 W. Maint New Kingstown, P A: c THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. if . . . "" = = "'- '-- s= ~ o -1'1 ::.;1 fi1::!J 1'"'- ,.,m ~nO '::),J- ~~::J ~"-) ,- ., ~~ " "T,' r-.) (J"j -0 ':;) C) OJ" ....:t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-2627 Plaintiff, vs. TYPE OF PLEADING: RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ" Praecipe For Entry Of Consent To Judgment Defendants, TYPE OF CASE: Civil Action Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOU tf COMPANY Defendants' Address: 60 W. MAIN STREET NEW KINGSTOWN PA 17072 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 HEATHER C. TROXEL, ESQ. PA ill NO. 91848 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANJA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No, 04-2627 Plaintiff, vs, RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ, Defendants. PRAECIPE FOR ENTRY OF CONSENT TO JUDGMENT TO PROTHONOTARY: Please enter judgment in favor of Plaintiff, BENEFICIAL CONSUMER DISCOUN~ COMPANY and against Defendants, RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ, in the amount of FOUR THOUSAND NINE HUNDRED THIRTY-TWO AND 81/100 ($4,932.81), with interest thereon at the legal rate of6% from JULY 1,2004, as evidenced by the Consent to Judgment attached hereto as Exhibit A. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. BY:~~~ Scott E. Crawford, Esq, 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, CIVIL DIVISION No" 04-2627 Vs, Plaintiff, RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ Defendants. CONSENT TO JUDGMENT '"1..../'~ AND NOW, to wit, this /9 day of /"1. ,2004, with the consent of all parties and their respective counsel, it is agre9tl a follows: 1. Judgment shall be and is hereby entered against Defendants RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ in the amount of FOUR THOUSAND NINE HUNDRED THIRTY-TWO AND 81/100 ($4,932.81) DOLLARS plus interest on the unpaid balance at the rate 'of 6% per annum commencing on JULY 1, 2004, 2, Defendants RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ agree to make payments to Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY in the amount of ONE HUNDRED TEN AND 00/100 ($110.00) DOLLARS on or before the 21ST day of each month for FIFTY-ONE (51) consecutive months, until the entire debt owing Plaintiff is paid in full. The first payment shall be due on or before JULY 21, 2004. 3. Payments shall be sent to Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY in care of CHROMULAK & ASSOCIATES, 1.L.C., 375 Southpointe Boulevard, 4th Floor, Canonsburg, PA 15317, or any other address Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY may later designate. ... . EXHIBIT j A 4, Defendants RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ have induced Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY, and Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY agrees to forbear in the enforcement of its rights against them so long as Defendants RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ make timely payments. If Defendants RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ fail to make timely payments, then Plaintiff BENEFICIAL CONSUMER DISCOUNT COMPANY may institute or take aU steps necessary, appropriate or helpful to collect the judgment, represented hereby, together with the Plaintiff s costs of collection and atto~eys fees therefore. AND NOW, on the date written above, the parties set forth their hands and seals as foUows: 7 W;m~, Rl:tJi;J, ~f~it~~d?--" q-~ Bk-flNCH~r~\~'.{ "p~ ~ ~frneY for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Scott E. Crawford, Esquire, counsel for Plaintiff, BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing PRAECIPE FOR ENTRY OF CONSENT TO JUDGMENT was served upon the following by United States First Class Mail, postage prepaid on this a01 nJ. day of ~\t ,2004: RICHARD SANCHEZ, SR. 60 W. MAIN STREET NEW KINGSTOWN PA 17072 BRENDA SANCHEZ 60 W. MAIN STREET NEW KINGSTOWN P A 17072 ~fWJ Scott E. Crawford, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~~\1; - () ~.... () ':\ ::2 ~ ~ ltf ft) C/) ~. ~ ~ p= -L- ~ .~-._1 ,-, "...., '-ii ~_,.. _...i : ,:- .) .,- '-", .- M~ (:"; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No, 04-2627 Plaintiff, vs" TYPE OF PLEADING: RICHARD SANCHEZ, SR. and BRENDA SANCHEZ, PRAECIPE FOR A WRIT OF EXECUTION Defendants, FILED ON BEHALF OF: and BENEFICIAL CONSUMER DISCOUNT COMPANY MEMBERS FIRST FEDERAL CREDIT UNION, Garnishee. COUNSEL OF RECORD: Plaintiff s Address: 2700 Sanders Road Prospect Heights, 1L 60070 CATHY ANN CHROMULAK, ESQ. PA 10 NO. 42067 MELISSA A. SHENKEL, ESQ. PA 10 NO. 91445 Defendants' Address: 60 W, MAIN STREET NEW KINGSTOWN, PA 17072 CHROMULAK & ASSOCIATES, L.L.C. Garnishee's Address: 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 Date: MARCH 1, 2005 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, CIVIL DIVISION No, 04-2627 Plaintiff, vs. RICHARD SANCHEZ, SR, and BRENDA SANCHEZ, Defendants, and MEMBERS FIRST FEDERAL CREDIT UNION, Garnishee. PRAECIPE FOR WRIT OF EXECUTION TO: The Prothonotary Please issue a Writ of Execution in the above matter, 1. directed to the Sheriff of CUMBERLAND County; 2, against RICHARD SANCHEZ, SR. , defendant, and }, against BRENDA SANCHEZ, defendant, and 4, against MEMBERS FIRST FEDERAL CREDIT UNION, garnishee, 5" and index this writ a" against RICHARD SANCHEZ, SR. , defendant, and b, against BRENDA SANCHEZ, defendant, and c, against MEMBERS FIRST FEDERAL CREDIT UNION, garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendants in any accounts, individual and ioint, personal and business. .f $4,569,27 - 37;t 9-.l. 7 $ 460.90 $ (840,00) $ 6" Amount of Judgment Additionallntcrest to Date Less Payments Received (Costs to be added) Pursuant to Writ of Execution And Service of Writ $4,190.17 1M ~- MELISSA A. HENKEL, ESQ. I THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~:;~ (J C') (:..;.) -0 C. .:.1'1 ~ ::".:.1 . _,..l - ~, ~ p % ij(~ ...... ~ l (: ~ -t: 'C \2; - ~ ~ ~ ./4. ~ ~-:O~ ~ () <--to ~ () C\)\)()O' I I I \-0 _ ~ ..~Y- -"~:t:> ~ :... ~ OC:.J T-+- - -!-r ~~J" :.>.: ...0 \'..) -. - WRIT OF EXECUTION andlor A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2627 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY; To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From RICHARD SANCHEZ, SR AND BRENDA SANCHEZ, 60 W. MAIN STREET, NEW KINGSTOWN, PA 17072 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to allach the property of the defendant(s) not levied upon in the possession of MEMBERS FIRST FEDERAL CREDIT UNION, 1166 WALNUT BOTTOM ROAD, CARLISLE, P A 17013 - SAID WRIT OF EXECUTION IS PURSUANT TO ALL MONIES DUE DEFENDANTS IN ANY ACCOUNTS, INDIVIDUAL AND JOINT PERSONAL AND BUSINESS GARNISHEE(S) as follows; and to notify the gamishee(s) that (a) an allachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (5) and from delivering any property of the defendanl (5) 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 Ihan a named garnishee, you are directed to notify him/her that he/she has been added as a gamishee and is enjoined as above stated, Amount Due $3,729.27 Interest - $460.90 L.L. $.50 Atty's Comrn % Ally Paid $82.00 Plaintiff Paid Dale; MARCH 7, 2005 Due Prothy $1.00 Other Cosls (Seal) CURTIS R. LONG protho~ p ~ . ~ a.-.,...fl /1/2.(1./ Deputy REQUESTING PARTY; Name MELISSA A. SHENKEL, ESQUIRE Address; CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone; 724-916-2400 Supreme Court 1D No, 91445 , ' SHERIFF'S RETURN - GARNISHEE . CASE NO: 2004-02627 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS SANCHEZ RICHARD SR ET AL And now VALERIE WEARY ,Sheriff or Deputy Sher'ff of Cumberland County of Pennsylvania, who being duly sworn accor ing to law, at 0010:10 Hours, on the 15th day of March 2005, attached as herein commanded all goods, chattels, rights, debts, credi s, and moneys of the within named DEFENDANT SANCHEZ BRENDA in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CRALISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BRIAN PETERS (BRANCH MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION a d made the contents there of known to His . Sheriff's Costs: Docketing Service Affidavit Surcharge so~~~ .00 .00 .00 .00 .00 .00 R. Thomas Kline Sheriff of Cumberland Cou ty 00/00/0000 Sworn and subscribed eriff me By ~iS ~r~ day of 1 . ()(~ A.. ' " ~. , - SHERIFF'S RETURN - GARNISHEE . CASE NO: 2004-02627 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS SANCHEZ RICHARD SR ET AL And now VALERIE WEARY ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn accord'ng to law, at 0010:10 Hours, on the 15th day of March 2005, ttached as herein commanded all goods, chattels, rights, debts, credit, and moneys of the within named DEFENDANT SANCHEZ RICHARD SR , in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BRIAN PETERS (BRANCH MANAGER) personally three copies of interogatories together with 3 t ue and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 ~~~i> R. Thomas Kline Sheriff of Cumberland Count 03/17/2005 n'( By 'J;IJ Deputy Sheriff Sworn and subscribed of me . ~'9f ---c-~lU IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-2627 Plaintiff, vs. TYPE OF PLEADING: RICHARD SANCHEZ, SR. and BRENDA SANCHEZ, PRAECIPE FOR A WRIT OF EXECUTION Defendants, FILED ON BEHALF OF: and BENEFICIAL CONSUMER DISCOUNT COMPANY AMERICHOICE FEDERAL CREDIT UNION, Gamishee. COUNSEL OF RECORD: Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 CATHY ANN CHROMULAK, ESQ. PA 10 NO. 42067 MELISSA A. SHENKEL, ESQ. PA 10 NO. 91445 Defendants' Address: 60 W" MAIN STREET NEW KlNGSTOWN, P A 17072 CHROMULAK & ASSOCIATES, L.L.C. Garnishee's Address: 20 SPORTING GREEN DRIVE MECHANICSBURG, PA 17050 375 Southpointe Boulevard 4th Floor Canonsburg, P A 15317 (724) 916-2400 Date: SEPTEMBER 7,2005 Ttll$ 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, CIVIL DIVISION No. 04-2627 Plaintiff, vs. RICHARD SANCHEZ, SR. and BRENDA SANCHEZ, Defendants, and AMERICHOICE FEDERAL CREDIT UNION, Garnishee. PRAECIPE FOR WRIT OF EXECUTION TO: The Prothonotary Please issue a Writ of Execution in the above matter, 1. directed to the Sheriff of CUMBERLAND County; 2. against RICHARD SANCHEZ, SR. , defendant, and 3. against BRENDA SANCHEZ, defendant, and 4. against AMERICHOICE FEDERAL CREDIT UNION, garnishee, 5" and index this writ a. against RICHARD SANCHEZ, SR. , defendant, and b. against BRENDA SANCHEZ, defendant, and c. against AMERICHOICE FEDERAL CREDIT UNION, garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendants in any accounts, individual and ioint, personal and business. 6. Amount of Judgment Additional Interest to Date Less Payments Received (Costs to be added) $4,569,27 - 3J.!/'I{.).. 7 $ 577.09 (1,105,00) $ Pursuant to Writ of Execution And Service of Writ $4,041.36 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~0r----- MELISSA A. SHENKEL, ESQ. - , \) ~ ~ """'"- -9 ...... 1.1> "'6Q. ..... (n "t - \. -.. 11) ~ \. . :-0 II) V) o g ~ 8 B 6 \ I I , Co ~~~~~ 'i- - ... ~ 'P -" ~+=- . --..( - ~ () r-' ,~ 0 (~., ;"':::':;;' -n ~ . (.0 .-, .," r I hi ~ ""'0 F. N -- , , -'~1 -'~ .: ) , 1 , , C:: , I '",. 0 ~D CO .< ~ -e. D ~ ~~ b_ ~ .- ..0 C0 ~ f' fI' c> lJ [\ -.0 ti:- t ~ ~ -IQ.. --. - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, NO 04-2627 Civil CIVIL ACTION - LAW Plaintiff (s) From RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ, 60 W. MAIN STREET, NEW KINGSTOWN, PA 17072 (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 AMERICHOICE FEDERAL CREDIT UNION, 20 SPORTING GREEN DRIVE, MECHANICSBURG, PA 17050 - ALL MONIES DUE DEFENDANTS IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $3,464.27 Interest $577.09 Atty's Cornm % Atty Paid $99.50 Plaintiff Paid Date: SEPTEMBER 12, 2005 L.L. Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name MELISSA A. SHENKEL, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4rH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No, 91445 SHERIFF'S RETURN - GARNISHEE CASE NO: 2004-02627 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS SANCHEZ RICHARD SR ET AL And now KENNETH GOSSERT ,Sheriff or Deputy Sheriff of Cumberland County of pennsylvania, who being duly sworn according to law, at 0012:00 Hours, on the 20th day of September, 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT SANCHEZ RICHARD SR , in the hands, possession, or control of the within named Garnishee AMERICHOICE FEDERAL CREDIT UNION 20 SPORTING GREEN DRIVE MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to EMILY KEAMMERER (SERVICE REP) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So answers: r-~ 'lCd. R. Thomas Kline7 r Sheriff of Cumberland County 09/21/2005 Sworn and subscribed to before me day of <) ..1""A"k _AI' A.D. ~' c.----') By Prbthon SHERIFF'S RETURN - GARNISHEE CASE NO: 2004-02627 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS SANCHEZ RICHARD SR ET AL And now KENNETH GOSSERT ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:00 Hours, on the 20th day of September, 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT SANCHEZ BRENDA , in the hands, possession, or control of the within named Garnishee AMERICHOICE FEDERAL CREDIT UNION 20 SPORTING GREEN DRIVE MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to EMILY KEAMMERER (SERVICE REP) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So ans~ ~ lllllt:'~_e R. Thomas Kline' Sheriff of Cumberland County 09/21/2005 Sworn and subscribed to before me this J-.3 day of Se.f".....t;j,1 k J-orJ~~~_, Pr thon~ By . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. 04-2627 vs. TYPE OF PLEADING: mCHARDSANCHEZSR.and BRENDA SANCHEZ, Praecipe to Discontinue Against Garnishee ONLY Defendants, TYPE OF CASE: and Civil Action AMEmCHOICE FEDERAL CREDIT UNION, Garnishee. FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ill NO. 42067 NANCY C. WILKINS, ESQ. PA ill NO. 94178 JESSA C. MARTIN, ESQ. PA ill NO. 201169 AMY L. SABOLCHICK, ESQ. PA ill NO. 94653 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. , ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-2627 Plaintiff, vs. mCHARD SANCHEZ SR. and BRENDA SANCHEZ, Defendants, and AMEmCHOICE FEDERAL CREDIT UNION, Garnishee. PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please discontinue this action against the above garnishee, AMEmCHOICE FEDERAL CREDIT UNION and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By: d( CA CHROMULAK, ESQUIRE NANCY C. ILKINS, ESQUIRE JESSA C. MARTIN, ESQUIRE AMY L. SABOLCHICK, ESQUIRE Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscribed Befo;;;me this blf day of IJR-it.- , 2006. o Pu Twp.: VI, ,... -non CClUnly My Ccmml8llon C.IIllfllb JUy 7, 2008 1.10mb.., Penn.ytvlnll AI.actlnon 01 Notaries THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 4 . CERTIFICATE OF SERVICE I, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Discontinue Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 28th day of April, 2006. AMERICHOICE FEDERAL CREDIT UNION 20 SPORTING GREEN DRIVE MECHANICSBURG, P A 17050 RICHARD SANCHEZ SR. and BRENDA SANCHEZ 60 WEST MAIN STREET NEW KINGSTOWN, P A 17072 a1 Cathy Chromulak, Esq. Nancy C. Wilkins, Esq. Jessa C. Martin, Esq. Amy L. Sabolchick, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. }.J (J ..{q. ~, ,~ ~ en co:> <:-~ ~ c_';'I"" -' Ci -' ~~. "..:l--" -:;...: \.--" C> --'~,\\:::-; - \ -, .- - '"'" ',c" . ~ ~ ~ '--',:' ..c:: -<:1 _..~ - -'" w ~ r:-? z5; ~ <.J'I "" 1- --. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2627 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From RICHARD SANCHEZ, SR. AND BRENDA SANCHEZ, 60 W. MAIN STREET, NEW KINGSTOWN, P A 17072 (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 AMERICHOICE FEDERAL CREDIT UNION, 20 SPORTING GREEN DRIVE, MECHANICSBURG, P A 17050 - ALL MONIES DUE DEFENDANTS IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 $3,464.27 Interest $577.09 Atty's Comm % Atty Paid $99.50 Plaintiff Paid Date: SEPTEMBER 12, 2005 L.L. Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name MELISSA A. SHENKEL, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, P A 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 91445 "CC:,-.:.;-r d IJ ''''''11J ~~~ ~ illnJ. 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: 36.00 3.56 Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage .3 7 Garnishee 18.00 TOTAL 181.43 ~ sf !J,ltJ l, Sworn and Subscribed to before me 1.00 12.50 70.00 40.00 this .iJ&L day o~ 2006 A.D. Prothonotary U'I :O,! '<-I Cl I 1""'<' cor' Ii -J c.:L) ~ Jl ;3':~ ! <" Advance Costs: 300.00 Sheriffs Costs 181.43 118.57 Refunded to Atty on 5/16/06 So Ans, wers; . ./ .J 1!"~_I'<~ R. Thomas Kline, Sheriff A I By cJ an t Q (}.- \3r\JLuJ b~ ~ ~ ~ " ~ ~ :!--~ '===tFiJ '==U=U ~ ./ ~ ). v.u ~ CRii1 CJ'L 5" ~ :J 50 ilL 11 f.5'1.r V - ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. 04-2627 vs. TYPE OF PLEADING: RICHARD SANCHEZ, SR. and BRENDA SANCHEZ, Praecipe to Discontinue Against Garnishee ONLY Defendants, TYPE OF CASE: and Civil Action . , MEMBERS FIRST FEDERAL CREDIT UNION, FILED ON BEHALF OF: Garnishee. BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MELISSA A. SHENKEL, ESQ. PA ID NO. 91445 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, P A 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-2627 Plaintiff, vs. RICHARD SANCHEZ, SR. and BRENDA SANCHEZ, Defendant, and MEMBERS FIRST FEDERAL CREDIT UNION, Garnishee. PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please discontinue this action against the above garnishee, MEMBERS FIRST FEDERAL CREDIT UNION and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOClA TES, L.L.C. By:/G{ ~ CATHY ANN CHROMULAK, ESQUIRE MELISSA A. SHENKEL. ESQUIRE Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscribed Before me this I? day of /VfJ/C.;,i... ,2005. ~/~ Not EALTH OF PENNSYLVANIA Notartal Seal MIcheIte L. WoIofa. Notary Public CedI Twp.. W88hIngton County My CcrnmIssIon EJCPII'8ll Jl.tIy 7. 2008 Member, PennsyfvIMII Alloclltton Of Notaries r THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Melissa A. Shenkel, Esquire, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Discontinue Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 19th day of April, 2005. MEMBERS FIRST FEDERAL CREDIT UNION 5000 LOUISE DRIVE P.O. BOX 40 MECHANICSBURG, PA 17055 RICHARD SANCHEZ, SR. BRENDA SANCHEZ 60 WEST MAIN STREET NEW KINGSTON, P A 17072 .LA~ 'G~ Melissa A. Shenkel, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. (.)-tQ 1'- ~ l. \) ~ () ~ -0 ~P=- J- X) ~ - ,- IN )...) ,.., C> --------- ~; () ,.-~'_' ~Yl C;1 ~._l 1-;1 r<'; " -.,." ,.-.'\