The URL can be used to link to this page

Home My WebLink About01-3087IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT CIVIL DIVISION 0uMP , Mo. 01- Plaintiff, TYPE OF PLEADING: VS. Complaint KAY L. SUCCA, TYPE OF CASE: Defendant. Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHRO~u~K, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLZCA&MURHAY Firm ~952 Defendant's Address: 450 Trimont Plaza I Orrs Bridge Road 1305 Grandview Avenue Camp Hill, PA 17011-1914 Pittsburgh, PA 15211-1205 (412) 381-7000 THIS IS AN A'I'[EMPT 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 CIVIL DIVISION COMPANY, No. Plaintiff, VS. KAY L. SUCCA, Defendant. NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONe, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT ~HEEE YOU CAN GET LEC, AL HELP. CUMBERLAND COUNTY BARASSOCIATION 2 LIBERTY AVE~u~ 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 cuMBERI~ COUNTY, pENNSYLVANIA BENEFICIAL coNSUMER DISCOUNT ~ coMPANy, No. ~1- 305 ? ~ plaintiff, vs. ~y L. sucCA, Defendant. ~ cONS~R ~ NOW coMES, the plaintiff, DISCO~ cOMPS, by its AttorneyS, Mollioa R MurraY, with its civil Action Complaint, the following of whiCh is a statement thereof: __ cONS~R DISCO~ CO~ is a 1. B~FICI~ · the duly authorized to conduct business corporation, of Pennsylvania with its principal office situate at Co~onwealth 2700 sanderS Road, ProspeCt HeightS, IL 60070, hereinafter referred to as .plaintiff". 2. ~Y L' suCCA is an adult individual residing at 1 orrs Bridge Road, Camp Hill, PA 17011-1914' 3. On or about March 26, 1996, Defendant entered into a Loan A~reement with the plaintiff, as evidenced by the Affidavit attached hereto as ,,Exhibit A" and incorporated herein- 4. pursuant to the Agreement with Defendant, plaintiff advanced f~ds to the Defendant. THIS IS AN A1'I'EMPT TO COLLEC~ A DEBT AND ANY iNFORMATION I-~ oBTAINED W~LL BE USED FOR 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 February 12, 1999. 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 One and 18/100 ($2,001.18) Dollars as of April 7, 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. WI{EREFOHE, Plaintiff claims damages in the sum of Two Thousand One and 18/100 ($2,001.18) Dollars, with interest thereon at the rate of 23.27% from April 7, 2001, plus court costs and attorneys' fees. Respectfully submitted, MOLLICA & MURRAY CATHY ANN CHROMULAK, PA ID NO. 42067 MiCHILLE D. SMITH, ESQ. PA ID NO. 74800 Attorneys for Plaintiff 450 Trimont Plaza 1305 Grandview Avenue Pittsburgh, PA 15211 THIS IS AN ATI'EMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR I~IAT PURPOSE. Beneficial Finence P.O. Box 10640 A Household Internafimel V~rgima Beach, VA 23450 Company Beneficial' AFFIDAVIT OF LOST NOTE I, thc undersigned, do hereby certify that I am the representative of the lender. I further certify that account~ ~l~ [~)O~,~',~ executed arevolving note loan agreement dated-.-~loQ~olC~vith monthly installments. The first being due on ~ I ~ [.01~'~ ~0 I furthercertify that after ~..~ the said revolving note loan agreement was either lost or destroyed and that there'is presently an outstanding balance of~ plus interest at the contract rate of ~ *C'~['~iIercent from ~ I~ 0i and reasonable RECOVERY SPECIALIST Sworn and subscribed to bef.0re ~me this ~.'~.~ay of ~/L~, 2001. N'~..~¥ PIJBLIC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 01-3087 CIVIL TERM Plaintiff, TYPE OF PLEADING: VS. Praecipe to KAY L. SUCCA, Settle and Discontinue Defendant. TYPE OF CASE= Civil Action FILED ON BEHALF OF= BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD= CATHY ANNCHROMULAK, ESQ. PA ID NO. 42067 MICHELLE D. SMITH, ESQ. PA ID NO. 74800 MOLLICA &MURI~AY 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 P~RPOBE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 01-3087 CIVIL TERM Plaintiff, VS. KAY L. SUCCA, Defendant. PRAECIPE TO SETTLE AND DISCONTINUE TO: The Prothonotary Please settle and discontinue the above-captioned action and mark the docket accordingly. Respectfully submitted, MOLLICA & MURRAY By: ~SQ. PA ID NO. 42067 MIC~ELLE D. SMITH, ESQ. PA ID NO. 74800 Sworn to and su~/bed Attorneys for Plaintiff befor~ me this =~day 450 Trimont Plaza of ~u~.,~ , 2001. 1305 Grandview Ave. ~ ~ Pittsburgh, PA 15211 Notary Public Nlsm Bro~es, Notary Public I ~, A~-~ I THIS IS AN A~M~ TO COLLE~ ~ ~ E~ ~. 19, ~ ~ A DE~ AND ANY INFORMATION ~,~-~~~ OBTAINED ~LL BE USED FOR ~AT ~R~E. CERTIFICATE OF SERVICE I, Michelle D. Smith, Esquire, counsel for Plaintiff, BENEFICIAL CONSUMER DISCOUNT COMPANY hereby certify that a true and correct copy of the foregoing Praecipe to Settle and Discontinue was served upon the following by United States First Class Mail, postage prepaid on this 20TH day of June, 2001: KAY L. SUCCA 10RRS BRIDGE ROAD CAMP HILL, PA 17011-1914 ~sq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SHERIFF'S RETUR/g - REGULAR CASE NO: 2001-03087 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS SUCCA KAY L STEVE WHISTLER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SUCCA KAY L the DEFENDANT , at 1235:00 HOURS, on the 7th day of June , 2001 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQ CARLISLE~ PA 17013 by handing to KAY L SUCCA a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Mileage 7.44 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 35.44 06/07/2001 MOLICA & MURRAY Sworn and Subscribed to before By:~~..~, \ ' me this ~(, ~ day of Deputy Sheriff ~ ~! A.D. ! 9rothonot ary ' '