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HomeMy WebLinkAbout10-4245IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., Vs. Plaintiff, CIVIL DIVISION ?Iv '(^ i59 y ?J WI David Varner a/k/a David L. Varner, Defendant(s). No. 10 - ydy5' 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. Qa. oo P b Amt Cumberland County Bar Association Or 13aga 32 South Bedford Street E ayy3o? 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, Successor in Interest to HSBC Bank USA, N.A., CIVIL DIVISION No. Plaintiff, vs. David Varner a/k/a David L. Varner, Defendant. Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 1039 Grahams Wood Road Newville, PA 17241 TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A. 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 401 Technology Drive Suite 202 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, CIVIL DIVISION Successor in Interest to HSBC Bank USA, N.A., No. Plaintiff, vs. David Varner a/k/a David L. Varner, Defendant. COMPLAINT AND NOW COMES, the Plaintiff, Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., by its Attorneys, Chromulak & Associates, LLC, with its Civil Action Complaint, the following of which is a statement thereof: 1. Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A. 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. David Varner a/k/a David L. Varner is an adult individual residing at 1039 Grahams Wood Road, Newville, PA 17241, hereinafter referred to as "Defendant." 3. On or about April 28, 2008, the Defendant entered into a written Loan Agreement with the Plaintiff, as evidenced by the Endorsed Check, a copy of which is attached hereto as "Exhibit A" and incorporated herein. 4. Pursuant to the Loan Agreement with Defendant, Plaintiff advanced funds to the Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5. Defendant is in default under the terms and conditions of the aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about December 27, 2009. 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 Seven Thousand Eight Hundred Forty One and 35/100 Dollars ($7,841.35) as of May 3, 2010. 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 Seven Thousand Eight Hundred Forty One and 35/100 Dollars ($7,841.35), with interest thereon at the rate of 22.979% from May 4, 2010, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC T-)ekCW8eA J?? 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 401 Technology Drive Suite 202 Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. *071000301* 04/28/2008 6615980630 This is* LEGAL COPY of your check _ You can use I l the same way you wouId . use the or IginaIcheck 0 O ru Ln ti ? t17 S a o rU fl M n ,a Ln m Cr t-3 rT O M a m 0 u T[L7l9e+eeD00ar01 lA?l ?? 'r7r4l7i111177797 a' d* Ad _12hr- t' ?• ''?'I?? I? N g n'?g? r nr ?uae ='2ri.v.uvM ? ?I({?I?I????Ii11iP IEW `?r c App4al 14,20 David L. Varner AAd041NT. S7,000.00 Seven Thousmd and NO/100 DOLLARS_ $atrdld atlmi rdW 34,20N Q Ci andorsernentilndTwo Farms of ID RegWnd. By f i d M n _ ---- - _ - • . - - -- • - -- 7 - 84 ten th s od you aeoapt ouro a dw* the Lack o 57le to a ?t7ra oI yoyr loan aeroerpent tbttgined in Furon 97. Irthis dfhris not ocupled, please ? v2 --45 W8 L e D y 4 2 _dpuoy ft th i k I l l ten t • avid will rvsa t n a at ng this chec oan Sign 1034 Grab=z Wood Rd. must W repaid rYfttl U tereet and fee s. NewAlle. PA L724L-9780 / IdNILIIWIIIId11 atN?IlI?6d??d1w61L.???IL,bLd&I A(...w•?.-? AimlowmwsutllnWm a?t7i9Q[if.4?3raae t; 27 i9?OOLtt: 43,L715i2733594a' 11e0 i OIA 316,18 4+: 2? 19 700 L it: 7 & 17 15; 17 3359 711' oil DODO70DOO0,ta W a? !- u cu r r C3 v c c m rwrswwE im ] 0 p W jr ' 04 - •e. ?? ,262?[ 4?5 0-4 `s r : C J dye ;? t= E.. E+ b., C ?+ *.? ]E s- Cka$- t r ti,r :3?! CIiG Jt'F=S ?i " # to c C T .??iL=? i'F ?t!' I ?l C3 ti; In Rl ii € l W ti`.aN In ru. 01 1% rU P 1! CID I.. %. ti o ru a o c6 a - iOc noterWOM Or wrW below this Ilrm4 da1 DLL 1Amount opener 017094 or+llC?? 711711IklUSWUUSULi? 5(117(IIXIU7II011001'32.91949742311170948 Be Iefi ?m?o? II?IIIIIIIII?II?IIIII?IIIIIIIII?I _ Pay""" Sample A. Sample aver or Seven Thousand and N01100 Not valid after: May 14, 2008 S 171 1.01 e w 144l Sample A. Sample April 2008 497RO71 PABENEFiCiALi 17 Bridgeville, PA 15017-2503 11111111111111111/111111111111111111111111111111111111111111 HSBC Bank USA. N.A 70-7001 Processed al 1301 East Tower Road scnaumourp. Iy?N""' 2719 Hsec aCCOnunltldaeArsaFOr oeap'o"snB OCr,ry April 14, 2008 AMOUNT: $7,000.00 I aye€'s Endorsement and Two Forms of ID Required. By dorsing the back of this check you accept our offer and ree to the terms of your loan agreement contained in Form # 2979PA(0410 8 )4 9 7. If this offer is not accepted, please destroy this check. Signing this check will result in a loan that must be repaid with interest and fees. AUTHORIZING SIGNATURE 0019004433611' 1:27L97001,0: 71,17LLOL709497110 Sign the back of this check, and cash or deposit it before the expiration date. BereftW A mberHSRCOGrotp C:hamers Valley ti'hnpping Center I025 Washington Pike Dridgeville.PA 151117 (412) 321-8011 Customer 1D No.: 497 4230170948 You can cash this check today for $7,000.00 Dear Sample A. Sample, To thank you for being a Beneficial customer, we'd like to offer you another loan. In fact, you can take the above check to any bank or currency exchange. By cashing it, you'll also automatically open a new line of credit for $8,000.00. Get money immediately - There are no forms to fill out, and you don't have to visit a Beneficial branch. Simply cash your check before May 14, 2008. Use the money over and over - This is a revolving line of credit, so as you pay it off, the money is yours to use again. Of course, you're only charged interest on the amount you use- it's easy to get more money - Simply come in with your check and we'll add an extra $2,000 to your loan offer. Please visit your local branch at the address above before May 14, 2008- Once you cash your check, we'll also send you a book of checks so you can tap into the rest of your credit. If you have questions,, just call us at (412) 221-8601. Whether you call or cash your check, there's no need to wait. Sincerely, Grin DeVincent Branch Manager, Beneficial P.S. To accept this loan offer, just cash the check above before May 14, 2008. If you choose not to accept this loan offer, simply destroy the check. Ill- Day Satisfaction Guarantee 13Le use we want you to be completely satisfied, we offer a Satisfaction Guarantee. If for any reason you arc not satisfi d with this loan and you repay it in full within Ill days after the loan funds are disbursed, other than with a refinance o(this loan with us, ur will refund any Intcrest chargl` , closing costs and fees. We will also waive any prepayment penalty applicable to your loan. Your tirsl payment will be 5185.011, and is based on the initial check amount shown above. Your monthly payln alt is based alt a percentage of your account balance and your monthly periodic rate of 1.975% (the.ANNC.AL PERCE\I:AGE RATE is 22.979%). The Account Agreement found on the hack contains a full ezplanatiou of the terms and conditions of your Personal Credit Une.Accounl, including finance charges, fees and nfher charges which mar apply. SPLCIAL NOI*ICL - Please see the enclosed document entitled "Privacy Statement" for important information on your rights. TMS IS ASOLiCITATION FOR ALOAn -READ THE ENCLOSED DiSCLOSVRES BEFORE SIGNING THIS CHECK. If you do not wish to receive any futhe' solicitation. Please call (412) 2 21-8 6111 You can choose to stop receiving "prescreened" offers of credit from this and other companies by calling toll-free 1-888-567-8688. See PRESCREEN & OPT-OUT NOTICE on other side for more information about prescreened offers. ??v,tarn(a ?nkNr I???IIIIN?IIII?IIII - 0-42:01 -MJfi ?9-IX1fg2i:k-i (Required) Name Phone Number ? DO NOT SNARE (see enclosed Insert) is FLO if *1 Y? Sd7 ge .eS ?? -00 g a ?? g too Mm g A ? ag lif PRESCREEN & OPT-OUT NOTICE: This "prescreened" offer of credit is based on information in your credit repo in ..,..g a you must meet certain criteria. This offer is not guaranteed if you do not meet our criteria [including providing acceptable property as collateral]. If you do not want to receive prescreened offers of credit from this and other companies, call the consumer reporting agencies toll-free, 1-888.667-8688; or write: Experian Opt Out, P.O. Box 919, Allen, TX 7 50 1 3-091 9, Equifax Opts, P.O. Box 740123, Atlanta, GA 30374-0123, Trans Union Opt Out Request, P.O. Box 505, Woodlyn, PA 19094-0505. Personal Credit Line Account Agreement-Fixed Rate In this Agreement -you- and -your means the borrow and co-bmrower (if any) who sign this Account Opener Chack. 'e', -us', and -our refer b Beneficial Consumer Discount Company. If you accept our Personal Credit Line Account offer this Agreement will govern the terms and conditions dihe Account We want you to understand how a Personal Creeh Line Account works. Read this camfuly am complete and sign our Account Opener Check in order b nrift le your acceptance of IheAccwnt. It more than one person signs. each will be reapon side for repaying all sums advanced under this Agreement. The data of this Agreement will be the date theAmwnt Opener Check Is signed. AVAILABLE CREDIT Your Personal Credit Line Amount is a revoving line of credit through which you may obtain R WS u p to a creel I liml we assign you. You nay obtain funds directly Ram us or through your speclal becks up to your available credit. Each check must be writen for at least $100 Your indlal credit limit is stated on the Rom. which is incorporated herein by reRren ce . Your-13ble credit is your credit limb less the total unpaid balance. including Finance Charges, on your Account. If you make ban payments by check we will adjust youravailable credit seven days afferwe receive your check to allow for check Clea ling. N you request funds in an amount that would cause you to exceed your available credit, we are rid obligated to honor your request. It we do lend you an amtou nt over your avahlabla crecit, you agree b pay us Ihal excess amount, plus Finn ca Charges, Iminsdomly. PROMISE TO PAY You promiseto pay us: (a) amounts bonoved underthls Agreement: (b) Finance Charges Administrative Charges (bad check charge and overlimil res). and oNer charges provided in this Agreement; (C) credit Insurencecharges, Vary, (d) cdlectbn costs permibed by applicable law, including reason' ble attorneys' fees (if the attorney is rid blur salaried employee) and courtcosts' and (e) amounts in excess of your credit limit that we may lend you, plus Finance Charges. PAYMENT. You may repay your entimoutstanding balance at anytime without penally 'bu may not use your special checks to pay any amounts due under this Agreement Becau es the Finan m Cnarge Is computed each day, you will contact us rega Ming the exact payoff amount for the day you Intend to make fu I payment If you do not pay the entire unpaid balance on your Account at once, you agree to pay al as el the minimum payment shown on your monthly statement at the address indicated on the mouthy statement Each payment recdved will be apples as fdbws' First. to any accrued but unpaid Finance Charges; Second to any unpaid Administralive Charges provided in this Agreement; Third, to any unpaid credit insurance charges: Fourth, to the unpaid outstanding balance of your Account (in cludng all other fees and charges you are obligated to pay). Any partd 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 Y nlm the amdu me ware borrowed. Any pan of ywr monthly payment to be applied to Finance Charges will be applied in the same manner. MINIMUM MONTHLY PAYMENT Ywrmnlmum monthly payment will be the gmaterd S25 or the amou nl determned by the monthly payment factor (as described below) pus any administrative or creditinsurancecharges rounded to the nearest $1.170. Once the amount d your minimum monthly payment is determined, this amcknl will remain Axed for subsequent billing periods until a new advance is posted to your account. When this occurs your minimum mouthy payment will be recalculate in them me manner as set forth herein. Your minimum monthly payment depends on the monthly periodic rate applicable to your accelml; and Is 44tennlnM by multiplying youra CCount balance times the applicable monthly payment factor percentage listed belav'. MnnMly Pwrionm Rarw though 1674% Momhiy Pavmwnf Factor 2.345'%,&amount balance overt. 6741.thmugh 1.601% 2.467'%of account balance over 1. all thmugh 2.072'/ 2.615%&account balance War 2.072'%thmugh 2.262%. 2.756% & accou hit balance over 2.262'%thmugh 2 452'%. 2 D99'%& account balance over 2.462%thmugh 2.642% 3.046%&amwnt balance over 2642%through 2.915% 3.337% of amount balance Wei-2.916% 1405% Of account balance ANNUAL FEE. You agree to pay an annual fee of $50.00 in this revolving credit plan The annual fee is due and payable on thedate that your Persdlal Credit Line Account is estabf shed and the subsequent annual fee on the same day d each subsequent yea r. You agree that this fee may be charged to your amount balance LATE CHARGE. If you do not pay any required Minimum Month I/ Payment within 15 days after it 16 due, you agree to pay a Isla charge or 1 l of the Minimum Monthly Payment due or, 520. which.var 1a greater (excluding any unpaid late cha rges and amounts due from prior bteng cycles). BAD CHECK CHARGE. If you pay by a check which is r&umed br any reason you will pay a bad check charge of S20. TERMINATION AND CHANGES IN THE AGREEMENT. We can terminate your right to obtain additional advances or change the terms of this Agreement, Including Increasing the Monthly Periodic Rate, adding an annual tee and/or other reed if permitted by appkcable law, at any time. Prior wrmw notice wit be provided 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 law. DEFAULT AND CANCELLATION OF AGREEMENT We have the right to require you to pay your entire balance plus all otheraccrued but unpaid charges immediately and to cancel your credit privileges under this Agmement because of (a) failure to make any payment when due under this AgmemenC (b) frequent overdrawing &your credit line; (c) failum to supply us with any information requested; (d) supplying us with misleading false. Incomplete & Incorrect information(6) breaking any of the pmmiles; teens or condebne that are contained in this Agreement; (q the hling of a bankruptcy petition by or against you or (g) the death of any borrower signing the Account Opener Check. Aterdefeull you will pay our court ccoll; reasonable a Johney s Res (t attorney is nd our salaried employee), and other cdlention costs misted to the default if not prohibited by applicable law BALANCES UNDER EXISTING CLOSED-END ACCOUNT You agree to pay ore the balance under your existing cbseGend loan account with us with your Personal Creed Line Account. ALTERNATIVE DISPUTE RESOLUTI ON. Terms & the Amtmlldn Provision le provide vwth tons Promissory Ndeand Diudosure and is incorporated harem by hall. CUSTOMER INFORMATION PRACTICES. You agree that the Department of Motor Vain Iles (or your slale5 equivalent of such cepartment) may release your residence address to us. should it become necessary to locale you. You agree that our supervisory personnel may Islen to telephone calls between you and our me esentstives In orderto evaluate the qualtyd our service to you. For more information regarding our privacy practices. please refer to the enclosed Privacy Statement. NOTICE You acknowledge recehing a copy of tree Agreement. Please see the enclosed for important Information ngam ng your right to dispute billing errors. CONTRACT UNDER SEAL This is a contract under seal and may be enforce under 42 PA C 5. § 5529(8) FINANCE CHARGE. This is the interest charged on the balance of ywr Account during each billing cyC le. The Finance Charge le call" from the dale thet each advance. check & charge IS posted to your Account. The Finance Charge is computed by multiplying the average ealy halance In your Amount in each billing cycle limes the monthly periodic rate. The average daily balance is determined b1' totaling a It daily unpa k halances in each thing cycle and dividing Metdal by the nu mber of days m that cycle. Adaiy unpaid balance is the amount eve each day excluding any unpaid Periodic Finance Charges but including curd it insure nice charges and Administrable Charges for prior billing cycles. To determine any billing period's Finance Charges.. multiply the Average Daily Balance by a Monthly Periodic Rate 1.915'%(22979%. ANNUAL PERCENTAGE RATE). 017094-PA-571-031904 22979PA(04/08)497 PAC48CRLB PA0463.04 VERIFICATION KRISTIN M. BROWN , Recover Specialist for Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A. Deposes and says subject to the penalties of 18 Pa C.S. Section 4904 relating to unworn falsification to authorities, that the facts set forth in the forgoing Complaint are true and coma to the best of her knowledge, information and belief. l I ? KRISTIN M. BROWN t i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~ti~~tit~ at ~u+rzbe~l;~~~ {, = ~ .~ a .~ ;:•: QFFi~6'~F 7h~S~!`EFYIFF ~,~j~ k!7 FIL~C~ 1t r ZQIQ JUL -1 PM 2~ GZ CUM~''"~- `Yi.L'A~a~ ~'fY PE~i~~~ Beneficial Consumer Discount Company Case Number vs. 2010-4245 David L. Varner SHERIFF'S RETURN OF SERVICE 06/28/2010 07:11 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2010 at 1905 hours, he served a true copy of the within Complaint and Notice upon the within named defendant, to wit: David L. Varner, by making known unto himself perso ally, at 9 Grahams Woods Road, Newville, Cumberland County, Pennsylvania 17241 its content a ~at t e me time handing to him personally the said true and correct copy of the same. DEPUTY SHERIFF COST: $38.80 June 29, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj CouniySuite Sheriff Telacsoft_ Irc. DAVID L. VARNER 1039 GRAHAMS WOOD ROAD NEWVILLE PA. 17241 Fl~.f . ~:i c:;` 2Ql~ JI'L ~ ~ -$r i ~ ~ G, CUTd'~ ~:.,~~1eY r~ . State of ( Pennsylvania ), ( Cumberland )County Cause/Case No. ( 10-4245 ) Beneficial Consumer Discount Comp. Plaintiff, Vs. David L. Varner Defendant(s) ("Defendant"), hereby answers the complaint of ("Plaintiff) for it's self alone as follows and generally denies the allegations due to the complaint based on lack of information and belief. First Affirmative Defense "(Agreement to Arbitrate) The credit card agreement may state that disputes may be resolved by binding arbitration. Defendant elects to have all disputes related to the credit card agreement resolved by binding arbitration." Second Affirmative Defense "(Amount in Dispute) The account balance claimed by plaintiff is not accurate and the total amount that is owed, if any, is in dispute." _+ Trird Affiira~stive Defense "(Financial Hardship) Due to a serious iu~al crisis, defendant does nat have sufficient fiords to pay the full amount of the tod debt, if any. I,M WRITING THIS RESPONSE TO LET YOU KNOW WHY I'VE NOT BEEN PAYING MY PAYMENTS. DUE TO MY WIFE BEING OUT OF WORK FOR A COUPLE MONTHS AND NOW HER NEW JOB FORCED HER TO TAKE A BIG CUT 1N WAGES. I WAS ALSO OFF WORK FOR ABOUT THREE MONTHS WITH A TORN TENDENT IN MY ARM. WE JUST GOT TO FAR BII3IND AND COULDNT GET CAUGHT BACK UP.INWHICH WE FELL TO HARD TIMES AND COULD NOT MAKE ENDS MEET. AFTER VEIWING ALL OPTIONS, WE HAD TO STOP PAYMENTS TO SOME OF MY LENDERS. BY ALL MENDS I INTEND TO PAY THESE ACOUNTS WHEN POSSIBLE. IN FEBUARY OF 2010 I JOINED A DEPT RELIEF PROGRAM IN ORDER TO DO SO. ITS HARD TO GET BY RIGHT NOW AND I APPOLIGIZE FOR YOUR INCONVENANCE AND MY EMBARRASMENT. I REALY DONT HAVE ANYTHING OF MY OWN, THE HOUSE AND CAR ARE BOTH FINANCE. WHICH I REALLY NEED A PLACE TO LIVE AND A WAY TO WORK. AS SOON AS THERE IS ENOUGH MONEY IN MY DEPT RELIEF ACCOUNT I'M SURE YOU`LL HEAR FROM THEM. THANK FOR YOUR TIIVIE. WHEREFORE, Defendant requests that: 1. Plaintifftakes nothing by way of his complain; and 2. For Defendam's costs of suit. Dated: Jul 14, 2010 Signattu+e DAVID L. VARNER Printed Name Defendant in Pro Per ~r ~ . ~,.: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COI7N~, PENNSYLVANIA e ! .~ ~ s ,_ aan ate- i3 PM ,,,-,; BENEFICIAL CONSUMER DISCOUNT CNIL DIVISI(~~'~~ - .: COMPANY, SUCCESSOR IN INTEREST TO r `' ~ ~ ~ HSBC BANK USA, N.A., NO. 10-4245 CIVIL TERM PLAINTIFF, VS. DAVID VARNER A/K/A DAVID L. VARNER, TYPE OF PLEADING' PETITION FOR APPOINTMENT OF ARBITRATORS DEFENDANT. DATED: AUGUST 11, 2010 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. FILED ON BEHALF OF PLAINTIFF: BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A. CATHY ANN CHROMULAK PA ID 42067 BETH ARNOLD HOWELL PA ID 203606 TERESA K. FUCHS PA ID 205696 JENNIFER M. PALONIS PA ID 205703 CHROMULAK & ASSOCIATES, L.L.C. 401 TECHNOLOGY DRIVE SUITE 202 CANONSBURG, PENNSYLVANIA 15317 (724) 916-2400 (724) 916-2411 (FACSIMILE) $2y.oD~- cwt ~a~ory ~~~~~7L Y ~. IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., CNIL DNISION' PLAINTIFF, vs. DAVID VARNER A/K/A DAVID L. VARNER, DEFENDANT NO. 10-4245 CIVIL TERM PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JiJDGES OF SAID COURT: Chromulak and Associates LLC, counsel for Plaintiff in the above action respectfully represents that: The above-captioned action is at issue: 2. The claim of the Plaintiff in the action is $7,841.35 plus interest thereon at the rate of 22.979% per annum from May 4, 2010. Plaintiffls counsel is not aware of any member of the Cumberland County Bar Association that would be disqualified to sit as arbitrator in this matter. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted CATHY ANN CHROIVIULAK PAID 42067 BETH ARNOLD HOWELL PAID 903606 TERESA K. FUCHS PAID 205696 JENNIFER M. PALONIS PAID 205703 DATED: AUGUST 11, 2010 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CHROMULAK & ASSOCIATES, L.L.C. 401 TECHNOLOGY DRIVE SUITE 202 CANONSBURG, PENNSYLVANIA 15317 (724) 916-2400 (724) 916-2411 (FACSIMILE) •~ ~~ ~ t• CERTIFICATE OF SERVICE I certify that a true copy of this Praecipe for Arbitration was served upon the following in the manner specified: Manner of Service David Varner a/k/a U.S. Postal Service David L. Varner 1039 Grahams Wood Road Newville, PA 17241 Pro-Se Defendant Cathy Ann Chromulak, squire Beth Arnold Howell, Esquire Teresa K. Fuchs, Esquire Jennifer M. Palonis, Esquire Dated: August 11, 2010 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~~ ~~ RECEIPT FOR PAYMENT Cumberland County Prothonotary's Office Receipt Date Carlisle, Pa 17013 Receipt Time Receipt No. BENEFICIAL CONSUMER DISCOUNT (VS) VARNER DAVID Case Number 2010-04245 Received of PD CHROMULAK & ASSOC IM Total Non-Cash..... + Total Cash......... + Change ............. - Receipt total...... _ 24.00 Check# .00 .00 $24.00 13607 .~.. y,..~.. ~ ... 8 / 13 / 201'0`""" 15:43:0;0`" 246.77i:6~ ~.,,.... Distribution Of Payment ------------- ------------------------ ----------- Transaction Description Payment Amount APPT OF ARBITRA 24.00 CUMBERLAND CO GENERAL FUNI $24.00 ~.. ;_ .«... F. ,,,,~„ ~...«... *..,,.. .... ,._ ..,,,,,, ..,,~,., ,.... ~_.~,,, ..,,. ~...,,,. +.,.,~. BENEFICIAL CONSUMER IN THE COURT OF COMMON PLEAS OF DISCOUNT COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., Plaintiff VS. CIVIL ACTION - LAW NO. 10-4245 CIVIL DAVID VARNER a/k/a DAVID L. VARNER, Defendant ORDER AND NOW, this l i a day of December, 2010, the appointment of David W. Knauer, Esquire, as Chairman of the Board of Arbitrators in the above-captioned case is VACATED. Keith O. Brenneman, Esquire, is appointed in his place. /ith O. Brenneman, Esquire Chairman, Board of Arbitrators Court Administrator :rlm lip" E.S rrt.-a? l BY THE COURT, Kevin . Hess, P. J. PL*x- i;? ?4L fem.."? ha rn [+ti ° _.i CZ) ?.. rv ' Js. fir ? rv .? "1"h BENEFICIAL CONSUMER The Court of Common Pleas of Cumberland I DISCOUNT COMPANY, n Plaintiff DAVID VARNER, a/k/a DAVID County, Pennsylvania No. 10 - 4245 L. VARNER, Defendant Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this C ommonwealth and that we will discharge the duties of our office with fidelity. I ?-? c%?y ? Signature ignature Signature Keith 0. Brenneman Stacy B. Wolf Alicia S. Miller Name (Chairman) Name Name Snelbaker & Brenneman, P.C. Wolf & Wolf Miller & Associates, P.C. Law Firm Law Firm Law Firm 44 West Main Street 10 West High Street 1822 Market Street Address Address Address Mechanicsburg, PA 17055 Carlisle, PA 17013 Camp Hill, PA 17011 City, Zip City, Zip city, zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) ?94tidst` K.yr04JAlt Rlre!1O- ??v?-Cc?olf.r Cvrfr o J &.j at c-fto.? . . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: March 2, 2011 (Chairman) Date of Award: March 2, 2011 Notice of Entry of Award Now, the q? wd day of U" , 20 // , at 1 0:00 , A .M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 3?50 • C 0 :)Cxy-ef By: Prothonotary Deputy FHA 1 t ' { 1-1 n ''r 1 , .. , HAS -2 A i..'r ri V. )ucl s { ? V G.( I? h C yy C-Op;es ?ka . le W -?Iali,, Ae IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., CIVIL DIVISION No. 10-4245 Civil Term Plaintiff, vs. David Varner a/k/a David L. Varner, Defendant. Date: April 4, 2011 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. TYPE OF PLEADING: Praecipe for Judgment on Arbitration Award c TYPE OF CASE: ' _ rn y- ...,? M Civil Action o 2> .. CD , FILED ON BEHALF OF: - ? ca-n Beneficial Consumer Discount O&-pan-y, rn Successor in Interest to HSBC BanU , N.A. 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 NATHAN A. MORGAN, ESQ. PA ID NO 202885 CHROMULAK & ASSOCIATES, L.L.C. 401 Technology Drive, Suite 202 Canonsburg, PA 15317 (724) 916-2400 Gil IflL/. a) (lGtf J'?aa5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., CIVIL DIVISION No. 10-4245 Civil Term Plaintiff, vs. David Varner a/k/a David L. Varner, Defendant. PRAECIPE FOR JUDGMENT ON ARBITRATION AWARD TOPROTHONOTARY: Enter judgment on the arbitration award in the above entitled case against David Varner a/k/a David L. Varner in the amount of $9,766.77 at the rate of 6% per annum, together with additional costs of suit. Respectfully submitted, THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CHROMU & AS OCIAT S By: • CATHY NN CHRO UL , 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 NATHAN A. MORGAN, ESQ. PA ID NO. 202885 Attorneys for Plaintiff 401 Technology Drive, Suite 202 Canonsburg, PA 15317 BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff DAVID VARNER, a/k/a DAVID L. VARNER, In The Court of Common Pleas of Cumberland County, Pennsylvania No. 10 - 4245 Defendant Oath Civil Action - Law. We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. A-- x - Signature ignature Signature Keith 0. Brenneman Stacy B. Wolf Alicia S. Miller Name (Chairman) Name Name Snelbaker & Brenneman, P.C. Wolf & Wolf Law Firm 44 West Main Street Address Mechanicsburg, PA 17055 Law Firm 10 West High Street Address Carlisle, PA 17013 City, Zip City, Zip Award Miller & Associates, P.C. Law Firm 1822 Market Street Address Camp Hill, PA 17011 City, Zip We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) . y 'Wfy o%< eye 1,9,4A11v717rd= Q/?d1 Q9A?I?t/S ! ? f/??Q N 7? t," 74 Gl ?iY?C? %1 N t ®f Ar q, '7G f.. 717 ?.f a4foi H: t 41Af ive-C r- ,V r 40J75- o -11 ?ftii t??¢ta.?v . . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: March 2, 2011 j (Chairman) Date of Award. March 2 , 2011 'Al A/ T1 Notice of Entry of Award Now, the c;? w day of ma" , 20 It , at 10:00- , A .M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 350. 00 20-e( Prothonotary By: Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A. CIVIL DIVISION Plaintiff, No. 10-4245 Civil Term vs. David Varner a/k/a David L. Varner, Defendant. TO: David Varner a/k/a David L. Varner 1039 Grahams Wood Road Newville, PA 17241 NOTICE OF ORDER OF JUDGMENT PLAINTIFF X DEFENDANT - GARNISHEE You are hereby ordered that the following Judgment has been entered against you on the day of 2011. X Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Default ( ) Verdict ( X) Arbitration a Prothonotary Deputy 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, Successor in Interest to HSBC Bank USA, N.A., Plaintiff, vs. David Varner a/k/a David L. Varner, Defendant, and Adams Co. National Bank, Garnishee. Date: June 8, 2011 c-, c•, r- -'= tom.., :? w COW THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 10-4245 Civil Term TYPE OF PLEADING: Praecipe For Judgment Against Garnishee TYPE OF CASE: Civil Action FILED ON BEHALF OF: Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A. 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 NATHAN A. MORGAN, ESQ. PA ID NO. 202885 CHROMULAK & ASSOCIATES, L.L.C. 401 Technology Drive, Suite 202 Canonsburg, PA 15317 (724) 916-2400 l q.OD fit. 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., Plaintiff, vs. CIVIL DIVISION No. 10-4245 Civil Term David Varner aWa David L. Varner, Defendant, and Adams Co. Nation Bank, Garnishee. PRAECIPE FOR JUDGMENT AGAINST GARNISHEE To the Prothonotary: Please enter judgment against Garnishee, Adams Co. National Bank, in the amount of $860.48 based upon the Garnishee's Answers to Interrogatories attached hereto as Exhibit A admitting possession of funds of Defendant in that amount, which is less than Plaintiff's judgment against the Defendant, interest and costs. Respectfully submitted, CHROM LAK & ASSOCIATES, LLC. By: Cathy Ann Chromulak, squire Beth Arnold Howell, Esquire Teresa K. Fuchs, Esquire Jennifer M. Palonis, Esquire Nathan A. Morgan, Esquire THIS IS AN ATTEMPT TO Attorneys for Plaintiff COLLECT A DEBT AND ANY 401 Technology Drive, Suite 202 INFORMATION OBTAINED WILL Canonsburg, PA 15317 BE USED FOR THAT PURPOSE. 9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER. DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA.N.A., Plaintiff, vs. DAVID VARNER a/k/a DAVID L. VARNER XXX-XX-8858, 1039 GRAHAMS WOOD RD. NEWVILLE, PA 17241 Defendant, and ADAMS CO. NATIONAL BANK Garnishee. TO: ADAMS CO. NATIONAL BANK 39 CARLISLE RD. NEWVILLE, PA 17241 CIVIL DIVISION No. 10-4245 CIVIL TERM You are required to file Answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. ALAS TO INTERROGATORIES TO GARNISHEE FIRST: At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him/her on any negotiable or other written instrument, or did he/she claim that you owed him/her any money or that you were liable to him/her for any reason: RESPONSE: No. SECOND: If your response to the previous interrogatory was anything other than an unqualified negative, set forth the amount of the claim, and identify the written instrument, if any, that forms the basis of the claim. RESPONSE: N/A. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT THIRD: At'the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the Defendant? The scope of this interrogatory encompasses, but is not restricted to, the contents of any bank account(s). RESPONSE: Yes. FOURTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: Savings Acaxmt No. 5577322 owned individually in the name of David Lee Varner, of 1039 Grahams Wood Road, Newville, PA 17241, with a balance of $1,160.48. FIFTH: At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the Defendant (or in which Defendant) held or claimed any interest. RESPONSE: No. SIXTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: N/A. SEVENTH: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which the Defendant had any interest? RESPONSE: No. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EIGHTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: N/A. NINTH: At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefore? RESPONSE: No. TENTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount, and state the date of the transfer and the name and address of the transferee(s). RESPONSE: N/A. ELEVENTH: At any time after you were served, did you pay, transfer or deliver any money or property of the Defendant or to any person or place pursuant to their direction or otherwise discharge any claim of the Defendant against you? RESPONSE: No. TWELFTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, in the case of monetary assets, state the amount, and state the date of transfer and the name and address of the transferee(s). RESPONSE: N/A. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. • THIRTEENTH: If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption and the entity electronically depositing those funds on a recurring basis RESPONSE: Yes, Checking Account No. 192414 awned jointly in the names of David Lee Varner or ChexYl J. Vanier, of 1039 iraiaub Wood Road, Wwville, PA 17241, with a balance of $1,418.14. FOURTEENTH: If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 PaC.S. Section 8123? If so, identify each account RESPONSE: No. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. DATE: -?{ - j/ By: Cathy Ann Chromulak, Esq. Beth Arnold Howell, Esq. Teresa K. Fuchs, Esq. Jennifer M. Palonis, Esq. Nathan A. Morgan, Esq. 401 Technology Drive Suite 202 Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. The undersigned verifies that the answers contained herein are free and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsifications to authorities. ACNB BANK, FORMERLY KNOWN AS ADAMS COUNTY NATIONAL BANK Dated: Sl AD I' I By: '.1 William A. Kauffman, Assistant Vice President CERTIFICATE OF SERVICE I, counsel for Beneficial Consumer Discount Company, Successor in Interest to HSBC Bank USA, N.A., hereby certify that a true and correct copy of the foregoing Praecipe for Judgment Against Garnishee was served upon the following by First Class Mail, postage prepaid on this 8th day of June, 2011: Puhl, Eastman & Thrasher 220 Baltimore Street Gettysburg, PA 17325 David Varner a/k/a David L. Varner 1039 Grahams Wood Road Newville, PA 17241 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Beth Arnold Howell, Esq. Teresa K. Fuchs, Esq. Jennifer M. Palonis, Esq. Nathan A. Morgan, Esq. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Beneficial Consumer Discount Company, Successor in interest to HSBC Bank USA, N.A., Plaintiff, vs. David Varner aWa David L. Varner, and Defendant, Adams Co. National Bank, Garnishee. CIVIL DIVISION No. 10-4245 Civil Term NOTICE OF ORDER DECREE OR JUDGMENT TO: Puhl, Eastman & Thrasher 220 Baltimore Street Gettysburg, PA 17325 (X) Garnishee You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on? ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $860.48 plus interest at the rate of 6% per annum and additional costs of suit. De 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 BENFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., Plaintiff, vs. DAVID VARNER a/k/a DAVID L. VARNER, Defendant, and ADAMS CO. NATIONAL BANK, Garnishee. CIVIL DIVISION: No. 10-4245 CIVIL TERM ?c o Z? c =M -<> © r ss o '? zo z°°=? DZ ?? ©M PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE ONLY TO THE PROTHONOTARY: Please satisfy the judgment in this action against the above garnishee, ADAMS CO. NATIONAL BANK, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By: ml Lw T(I &;Ir CAVY AI14N CHROMULAK, ESQ BETH ARNOLD HOWELL, ESQ. TERESA K. FUCHS, ESQ. JENNIFER M. PALONIS, ESQ. NATHAN A. MORGAN, ESQ. Attorneys for Plaintiff 401 Technology Drive Suite 202 Canonsburg, PA 15317 Sworn to and subscribe Before me this 7-Z day of , 2011. ?..44U Notary Public CnNIMONW &TH OF PENH VM K L LNNot3rial al Heather Lrotary publk CecilTwtocCounty My CommisJune 29, 2014 Member. PennwNanie Assodation of Nomft THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. a* %Scv pd a Ck9 1530b 1-44 P? &D97 $ CERTIFICATE OF SERVICE I, counsel for BENFICIAL CONSUMER DISCOUNT COMPANY, SUCCESSOR IN INTEREST TO HSBC BANK USA, N.A., hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy Judgment Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 22ND day of JUNE, 2011. EDWARD G. PUHL, ESQ. 220 BALTIMORE STREET GETTYSBURG, PA 17325 DAVID VARNER A/K/A DAVID L. VARNER 1039 GRAHAMS WOOD ROAD NEWVILLE, PA 17241 C thy Chromulak, Esq. Beth Arnold Howell, Esq. Teresa K. Fuchs, Esq. Jennifer M. Palonis, Esq. Nathan A. Morgan, 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 ) ) Plaintiff ) NO. 104245 ) ) ) ) ) ) ) ) v. DAVID VARNER Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT Filed on behalf of: BENEFICIAL CONSUMER DISCOUNT COMPANY Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 q. coP d ow/ Cas! 2,�3o66s/ PA 147 Prcp Sat Jg P&F File No. 13-2273 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY ) ) Plaintiff ) NO. 104245 ) ) ) ) ) ) ) ) v. DAVID VARNER Defendant(s) PRAECIPE TO SATISFY JUDGMENT TO: PROTHONOTARY Please satisfy the Judgment at the above captioned action of record upon payment of your costs, only. Thank you. Date: May 21, 2014 Respe P reg 213 E. a Carnegie, PA 15106 (412) 429-7675 4ubmitted: e & Felix, A.P.C. . Morris, Esquir PA_147 Prep Sat Jg P&F File No. 13-2273 I, GREGG MORRIS, attorney for Plaintiff, BENEFICIAL CONSUMER DISCOUNT COMPANY , hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: DAVID VARNER 1039 GRAHAMS WOOD RD NEWVILLE PA 17241-9780 Date: May 21, 2014 squire elix, A.P.C. ain Street Carnegie, PA 15106 (412) 429-7675 PA_147 Prcp Sat Jg P&F File No. 13-2273