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Home My WebLink About02-0008IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, vs. DANA M. HAAS, Plaintiff, Defendant. CIVIL DIVISION TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL Defendant's Address: 502 North Bedford Street Carlisle, PA 17013 60070 FILED ON BEHALF OF: BENEFICIAL 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, BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. DANA M. HAAS, CIVIL DIVISION No. O~ -- O2 Defendant. NOTICE TO DEFEND PENNSYLVANIA 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 AFFORb 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 BENEFICIAL CONSUMER DISCOUNT COMPANY, vs. DANA M. HAAS, Plaintiff, Defendant. AND NOW DISCOUNT COMPAI~Y, Civil Action Complaint, thereof: 1. Corporation, CIVIL DIVISION No. Oa-- COMPLAINT COMES, the Plaintiff, BENEFICIAL CONSUMER by its Attorneys, Mollica & Murray, with its the following of which is a statement B~lg~FICIAL CONSUMER DISCOUNT COMPANY is a 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. DA~A M. ~IAAS is an adult individual residing at 502 North Bedford Street, Carlisle, PA 17013. 3. On or about March 19, 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 April 21, 2000. 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 Two Thousand Five Hundred Six and 52/100 ($2,506.52) Dollars as of November 15, 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 Two Thousand Five Hundred Six and 52/100 ($2,506.52) Dollars, with no interest, plus court costs and attorneys' fees. Respectfully submitted, MOLLICA & MURRAY By: CATHY ANN CHRO~, 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. ,~"' '~ ii'"' ', ;. ,.4N 'RE~'~MENT AND SECURITY AGREEM]~NT (Pase:l"di 3) S~NE F I,C.I AL' CQNS~ER' ~:1SCOUN:T CO. ANY 41g STONEHEDGE DRIVE '. ;.: , LOAN NO: ~1-~ 715~504g] 1 ,~ mYra' ~AT~ 031 63. OO lal .70 NON( :.. ¥0U iNTEREST COVERING: OESCRIPTION IP SEE ATTAT SEC 1 I ~£~umm) ~su~,.~, ~._~ou m~ ~i. ~,,..= ~o, =,= of ~. ~"~'~S .~,~7 ~, ~'~-:~t~:' ~" '"4'~' ~?' I ' ' j '::/:.' :' .::: 'Rhy~l lgm~ i~a~ o~ *~le ~ ~r "~u~" a~ ~ ~y~. ,~r~ ~r:"l-~,*~".. ' ... I NOTICE. T~ FOLLOWING PAG~ CONTAIN ADD~ION'AL CO~' TERMS. . EXHIBIT : . ; ' / LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3) PAYMENT. In return'fOe this loanl you will pay ua the Total of Payments'(the ~um' of Finance Charges plus Amouni Einanced), in mm4tMy .i:iayment-s atoned' on l~ge one. The ~nam:e Charg* is the'total of lnmr~t plUs Service. Charge, You , may:pay more at any time. Yoh will pay u~ at our bmine~ addr~a aa stated on pago'one or oth~r ~ddr~ g~v~n you, If more than one Borr0wm; is named off page one, we may enforce tiffs Agreement agalnat all, or any, Boer°wem,-~ui hot in a . comb!?ed amount greater than the sm0bnt owed. DATE O~ WHIC~.FINANCE'CHAI~SE BEGINS. Hnane~ Ctmrgaa l~gin onthe date o{ disbu~m~nt. If thia.il0,r~ is made by mail, th* date 0n ~hi0h th~ Finance Charge begitm ia po*tponed bythe riumb*r of'days frOm the date of tN, Agr~ment to the dite of disbur~ment: Paym~nz dm dat~ and eff~ctlve dambf any optional insurance purc~ are ~. P. AY-O}~P& you ~gree to par-0uta: o~'Amount FinancJxl .a shown on Trutl/~h:L~ndin~ dimlosui:e form. If pay-Gum , : enange lJecaU~ loan.¢lnsing is dclayeCi,:(a) you shall pay additional amounts due st ¢lOs/ng, or (b) yolur c,$sh or ch~lt will be redu6ed to ¢o4er additional pay-outs;": ' - · PREPAYMENT. If ~u fuIiy paY.bof6re final paym*nt du~ dat~, the amount you owe wHl be reduced By unearned F~/ianc. · Charge (bu~; qOt Se:r.v!o¢ Char~,e~ dotermi,ned by the 'Rule of 7$the2 :' '., ~ '; ' · MATURITY..~[te(~lSe finaL:payment c!~tu~ date stated on page one you will pay~[ntea'est 'at tho'r~te 0it 18% l~r yea~.~: · · ATE CTHARGE. If.you: don t an m~mt .... "' ; '' · ' ".' '. .... :..~ $ other~, .le,~ d!sho~r~.....yo? ~,gr~ tha~:~e may d~duet this charge from a montl~l~f.pa'ymen~:' ' ' ': .... "::. FAILUt~_.TO:PAy:i, If ~ou don't ~y inl' psi'merit on time or t~il' to keep any required instance ih t'or~, fa) *il y~ui- paym~mts m~y ~me .due at 9nee snd~Without notifying you be~o~ bringin~ ~t R, we may ~ Rk the to,al ammi~l ou a[tomeg.~oes, tr me attom¢l' ts.not our ~a!an*d ¢mplol'oo, for lel~l procee~ling$ t/~501t~et thin. Iota;or ~..alizo:on.~Ui.ily.i.: ng you from. Greets, stlcll as~ *tOm, oth~ lmldera, and credit reporti:g 'agencies Yo~J 'au/.h0riZe us to ah~i~ in~ ' expe~i~ces .betw~ ~sand yon) b~:~nd~g a written r~ucst which c~n~alhs,your full.nnmc Social Secut~ty - NUm~ and Add~eSs to:ua:~t?.O.'B6x 8~2, Elmhurst, IL ~126. .. .. ~ = If-you/fail:t0 fulfiU:the.term; of yo~ cr~it oMi~t{o~ a negative re~r~ ~fl~ing. on'. you(~it ~rd may ~; ~.yY~ ~nn¢ mai u~n ? ~l~phono ~la ~tw~ you ~d our ~fi~ ~ o~d~ m ~VaI~ ~O '" '. ~' NO~c~: 'T~E FOLLOWING PAGE CONTA~S ADDI~ONAL CONT~~ jERMs' PAB75002' r BO~I~OWERS: WITNESS: !(SEAL). · '~': "' ii ·: OPTioNAL PERSONAL PROPERTY PROTECTION (Page I of 3) '. DEF~ITIONS: (zip) (Not Appli~'~ble to MOlO~ Vehl~l~.~ and M~bilei~I-]ome~): YOU have offer~ ~nal ~. ~ s~u~' for your I~n. We ~ve only ~c~ ~ of thcjOffor~ ~fleb ~o~y putc~ $~s pf0~ion t~ough ~:~ from any ag~t or ~. You m~ al~ p~o~'a~tlom[ ~ pr~Y that you oWn {~C[u~g motor ~c[~ and mo~le hom~ ~ to ~ amount ~q~. ~o tho ~ia~m=n~ ~ vd~ 9f tho imU~ ptq~"0r '~ ~moont-~anc~ ~own on ~e ~ Ag~m~ X~. any-f/ling and ~ding. f~ {~0 'if t~ [~ i~[ ~ ~y,~l ~y ~d ~3~.~ if the ~o~ i~ ~C~~ by a mort~g~ o0-v~ p~o~)~ [~ur~qe c~ .and p~mj~m~ ~ ~ m~mum of S~,~ (Maximum ~v~gc), which~er, is ~;. 'We hav~ ~k~if ~o~ have s~ ~t~on on the ~1 ~rty. Your r~ly i~ ~ foIlow~ L ,; ~;~. :. ~ ;~' ~u ~no pro~fioa and wish xo buy ~he ~on off~ ~h~ugh ~. · ~ ~cn??Br ~o~r of your chol~. Yo~ i~rin~ Comply W~I: nam~ m ~ 10~' · ~ to buy the ~ton off~ through ~:'~c a~ ~ r~urn ~e f~ll premtum if ' I0~ :":: ~-,-: :' . ' , .,', ,, ; ' . ,;.', ' ~E ~e buying ~e ~o~ p~9~tton off~ ~?u~ ~ ~ shown ~t or full ~la~ent co~ : no ~t tot de~a ' ,~, ~q~ko, flood, and c~ ~ ~' d~i/ble. ~r~ary, - (,, ~:,: ' : "' ...... :': .:'- ~ · ~'":7 (~mum - ~,~) - (M~mum - 60 ~ont~l ' ..~L- '' ms' ' ' ~.:/ S ~oo.oo ' S' 036 " .',~V, ?: ...... .' ~ou and your refer to all Tho words we, us, and LENDHR : We will ., make to you, Any property bc wr[t:T~m, by i?affilla~ed with ua, (hereinafter .. ..... Otto of our employe6a'is pldy~ ia not acting as agent, broker, or [ido¢ia~ fgr you 0a 't*hfis ~r~0.saction. The agen'~ r i'ealize some benefit from the ~als of pr~y insuranc~, ('het=insf t~r Account Number 0050/+971 · ' .' - i. . ~.: ;i EXI~BIT1 ValuaXioa of Personal Property (SEARED PLUS) . ~,: 'Adzlre~J" '' 50Z~ S. ',~ S~'~ Da~' ?:0'3/'1~/9~'. · · .;. -!; := · . :.: .,o,.. IflllllliEIIIIlffilHIllllil~iilfllllillllllBgil (Pac~ 1, of. 2) LOAN.NO: 71:17.1~-5o4o~ 1 following page contains additional information. ' IIlllllillllilllillIliIIllIItillll $ · kNNUAL i ' ~I:INANCE;,'. Amount TotalofPaymenl~ Date - . · ~ : : RATE ":7:'The" do~? amo~~':: The amount of ~r~i' haw~ia~r ~u ,L~n , ' :: the erst will ~t ~o~ ~ ~OU or ~ have ma~ aH ~y- ' ' SECURITY,: YOUL',A~E GI~ING .US A SECURITY INTEREST IN: ~':":7~' ~yone you w~t ~hat iS ~p~ble to ~ If you pm~ P~I Pm~y l~ran~ ~PPIJ' ~mugh . , , .. , r i "TRUTH--IN--LENDING DISCLOSURES (Pag,~ 2'of 2) ' ~'" ~R~D,~ LIFE NsuRANcE: "I~AID' T-0 NSURANCE COMPANY) : ........ ,,: ~.,$ ' ' ~" CREOti I NVO~bN~E~"UNEM~[O~MENT INSURANCE (PAID TO I NSURANCE,CO~ANY), .,':(...'~ ~ ',: CREDIT PROPERT~ N~URANCE(F~[~ TO NSURANCE COMPANY) ,, . , ~ $ 3~,,25,'~ ' IIllilillllIlllillllilllllliil VERIFICATION Patricia Garcia, Recovery Specialist for BENEVICIAL CONSUMER DISCOUNT CO/~PANY. 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, information and belief. Pat~icia Garcia THIS IS AN A'/', r_MPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR TI-IRT PURPOSE. SHERIFF'S RETURN - CASE NO: 2002-00008 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS HAAS DANA M REGULAR KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HAAS DkNA M the DEFENDkNT , at 2055:00 HOURS, on the 2nd day of January , 2002 at 502 NORTH BEDFORD STREET CARLISLE, PA 17013 DANA HAAS a true and attested copy of COMPLAINT by handing to & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this ~ day of ~ ~l~ ~,l~ A.D. I ~rothonota~y ~ ~ J So A~swers: R. Thomas Kline 01/04/2002 MOLLICA & MURRAY BY: /~D~put~gh~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, vs. DANA M. HAAS, Plaintiff, Defendant. CIVIL DIVISION No. 02-08 Civil Term TYPE OF PLEADING: Praecipe for Default Judgment TYPE OF CASE: CIVIL ACTION FILED ON BEHALF OF: 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 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 Defendant's address: 502 North Bedford Street Carlisle, PA 17013 MOLLICA & MURHAY 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 within-named defendant, DANA M. HAAS, for failure to file an Answer as follows: Amount claimed in Complaint: $2,506.52 Interest from 11/16/01 thru 2/05/02: -0- Costs of Collection thru 2/05/02: 554.50 TOTAL $3,061.02 with interest accruing on the total balance of $3,061.02 at the rate of 6% per annum, together with additional costs of suit. By: ~,~~' ~ CATHY ANN 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 January 24, 2002 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attached copy. CATHY ANN CHROMULAK, ~SQ. MICHELLE D. SMITH, ESQ. Sworn to and subscribed before me this ~ day of~, 2002. ~ublic ~ Notarial Seal Yvonne Gardner Jones, Notary Public Pittsbu~h Alle~lheny County My Commission Exp*res Jan. 29, 2005 Member, Pen~ylvania Association ot Notaries 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 No. 02-08 vs. DANA M. HAAS, Defendant. TO: DANA M. HAAS 502 North Bedford Street Carlisle, PA 17013 DATE OF NOTICE: January 24, 2002 iMPORTANT__NOTICE YOU ARE .IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEAR3kNCE 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: CATHY ~ CH~OMULAK, ESQ. MICHELLE D. SMITH, ESQ. Attorneys for Plaintiff 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 CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, No. 0~-08 CIVIL TERM vs. DANA M. HAAS, Defendant, and MEMBERS FIRST FEDERAL CREDIT UNION, Garnishee. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: BENEFICIB-L 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 No, 952 1305 Grandview Avenue 450 Trimont Plaza Pittsburgh, PA 15211 (412) 381-7000 THIS IS AN Am ] ~..~#~T TO COLLECT A Dr..ul' AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. No. 0~-08 CIVIL TERM ~DANA M. HAAS, Defendant, and .~2MEMBERS 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 DANA M. HAAS, defendant, and 3. against MEMBERS FIRST FEDERAL CREDIT UNION, garnishee, .. 4. and index this writ a. against DANA M. HAAs, defendant, and b. 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 joint, personal and business. 5 o Amount of Judgement $ 3,061.02 Additional Interest to Date $ 10.71 (Costs to be added) $ Pursuant to Writ of Execution and Service of Writ $ 3,071.73 MICHELLE D. SMITH, ESQ. ITHIS IS AN A ~, udPT TO COt ~ r-CT 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, vs. DANA M. HAAS, and Plaintiff, Defendant, MEMBERS FIRST FEDERAL CREDIT UNION, CIVIL DIVISION No. 02-08 CIVIL TERM TYPE OF PLEADING: Praecipe to Settle and Discontinue Against Garnishee ONLY TYPE OF CASE: Civil Action 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 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 BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 02-08 CIVIL TERM Plaintiff, vs. DANA M. HAAS, and Defendant, MEMBERS FIRST FEDERAL CREDIT UNION, Garnishee. PRAECIPE TO SETTLE AND DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please settle and discontinue this action against the above garnishee, MEMBERS FIRST FEDERAL CRDIT UNION and mark the docket accordingly. By: Respectfully submitted, MOLLICA & MURRAY CATH~ ANN CHROM~LAK, ESQ. MICHELLE D. SMITH, ESQ. Attorneys for Plaintiff 1305 Trimont Plaza Suite 4504 Pittsburgh, PA 15211-1205 Sworn to and subscribed befDre me this ~/J~- day f/l/J rr3] , 2002 / · N6tary P~lic - ' THIS IS AN ATTEMPT TO COLLECT IA DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Michelle D. Smith, Esquire, counsel for BENEFICIAL 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 21st day of March, 2002: DELICE MURPHY, CFE MEMBERS FIRST FEDERAL CREDIT UNION P.O. BOX 40 MECHANICSBURG, PA 17055 DANA M. HAAS 502 NORTH BEDFORD ST. CARLISLE, PA 17013 Michelle D. Smith, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-00008 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS HAAS DANA M And now DAVID MCKINNEY ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:37 Hours, on the 12th day of March , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , HAAS DANA M , in the hands, possession, or control of the within named Garnishee MEMBERS FIRST FEDERAL CR UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to TAMMY MISLYAN (MANAGER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her true and made Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this J~ day of'h4~3-2 ~4~o 2~ A.D. Prot~6t ary So answers: Sheriff of Cumberland County 00/00/0000 - ~e~ut'y S%leriff ~ R. Thomas Kline, Sheriff, who being duly swom 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 SherifFs Costs: 73.38 76.62 Refunded to Atty on 3/25/03 Sworn and Subscribed to before me this Z.v?- da~ o_.,f ~ A.D. pro~onot~ So Answers; R. Thomas Kline, Sheriff By