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HomeMy WebLinkAbout04-4772 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. QlI- "I11~ C;u~L 'T~ Plaintiff, TYPE OF PLEADING: vs. Complaint DENNIS J. HAGERlCH alk/a DENNIS HAGERlCH, TYPE OF CASE: Civil Action Defendant. FILED ON BEHALF OF: Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Defendant's Address: 6167 HAYMARKET WAY MECHANICSBURG, P A 17050 CATHY ANN CHROMULAK, ESQ. P A ill NO. 42067 SCOTT E. CRAWFORD, ESQ. PA ill NO. 89570 HEATHER C. TROXEL, ESQ. PA ill NO. 91848 CHROMULAK & ASSOCIATES, LLC 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION No. 04 -.1./77).... C:lc.>~lJ~ VS. DENNIS J. HAGERlCH a/k1a DENNIS HAGERlCH 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 OBTAINED WILL BE USED FOR THAT PURPOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04 - Jj'7?~ C?;uJJ~ Plaintiff, vs. DENNIS J. HAGERICH aIkIa DENNIS HAGERICH, Defendant. COMPLAINT AND NOW COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, by its Attorneys, Chromulak & Associates, LLC, with its Civil Action Complaint, the following of which is a statement thereof: 1. HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY is a Corporation, duly authorized to conduct business in the Commonwealth of Pennsylvania, with its principal office situated at 2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred to as "Plaintiff". 2. DENNIS J. HAGERICH aIkIa DENNIS HAGERICH is an adult individual residing at 6167 HA YMARKET WAY, MECHANICSBURG, P A 17050. 3. On or about AUGUST 5, 2003, Defendant entered into a written Loan Agreement with the Plaintiff, 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 ofthe aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about MAY 29, 2004. 6. Pursuant to the terms ofthe Loan Agreement, Plaintiff has the right to require payment of the entire amount owed upon default. The total amount due, and owing by the Defendant is in the sum of FIVE THOUSAND, SIX HUNDRED 75/100 ($5,600.75) DOLLARS as of AUGUST 4, 2004. 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 costs of coJlection and reasonable attorney's fees. WHEREFORE, Plaintiff claims damages in the sum of FIVE THOUSAND, SIX HUNDRED 75/100 ($5,600.75) DOLLARS, plus court costs and attorney's fees. RespectfuJly submitted, Chromulak & Associates, LLC BY:~ CATHY ANN CHROMULAK, ESQ. PA ill NO. 42067 SCOTT E, CRAWFORD, ESQ. P A ill NO. 89570 HEATHER C. TROXEL, ESQ, PA ID NO. 91848 Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. --p', - dl~ r ~~!o ~ · f ':S-~ s :Z:"'O" .. :..!:::r:"~ " a <: 8 ..,. o ;- i.r~ ... ~ t'rll:l tJ ~ :... 0' B a:: i g; 5! ;;:' o =- ~ R.~ .. 0.... .,."to> -'11~ ~c:::::t;;>1"" ~ L~~g: lltfJr: IJ!:S? o :'::>~ :~g "* r : 0 11:lS: ell) o :-? s ~ ~~ ~ ~ ~ r 0 'l_~ _ ."" ~ t. ~ ~ ~i; ...~ .,Jr : so ;;;()l i.. .. _ .. _$' .0 .>.', =- .. !!iiI! I. !! ..,). ;.::: .~= ......._ Cl Ii o ! '" :t., ll>". 2 f D' ..' ~ .... IS \." . . i!; 0.- ~I: -,'", .. ..." ill:'. ~. '. .' . , . .,(Z}C!) 0 iii ",i ..._ <.. ,'. . '''. (\) 'J Ul ....::;... . ", ,............. Co! . . , ',' ", . i-'/. =at..... ~ -.3.... ..~..: ". ',:. '.' ,'!P. UlUl -l;:" 1 , _, .,', ,\1 - '" or' ~:..., if!!'~ ... co ~~:, ~~~''i'i:~~'<i' :!\Loti!. .-~;; " ,!;l -_, .". 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'. ib:3U . i!!l...l1j r !,,:r~ th I -3ji I !!!.., I D.~ PROMISSORY NOTE AND DISCLOSURES CREDITOR (Called We', -Us', 'Our'): &.Mftdll CorIIlI...,.Ditcounl CofftplItlJ 352S CoItmefl Avenue Philadelphil, PA19149 BORROWER (Called 'You', 'YOOr'): SIfnllltASlmpIe 123 Main St Any\own,PA 19135 . ANNUAl PFRCFNT.Ar.F IlAIE. TllIltoald)'Ollltfdllll year\yl'lle. . FINANCF CHAR". Tl'ledobrl/TlCllllr'lltl'tlcredJI """"'" Amount F;"nced Ttle.mounlrlcredft prcwdedlO)'OlIOfOll "..._. Tot,l of Payments Tile ,mounI you wlU/IIve ptJd,lttryoul\mrnllltall Pil)'mtnts..~1IItd $.,191.00 Dalel O~ ~ L'~'S' 21.1911. $4,117.12 'e" $5,000.88 '.' 1illft:hz.4,2OO3 'e" YourPlytnaftlsdteduled": I .._;- ..~ .JOU,.,......-,ou:~_......'D.,.,...1lf_lIII...Fm...c.en.,... AIIlovnIDfPa)'ll*lts $153.30 Whlin hi"" A/II Out: Montflly, bIgitlning on the Paymfflf DIJ8 Dale.shown on !he first Billing _. .... C1NNge: ......._'....,.,.,. ~..,."", ......w. due,,.,.,......,.,. '.In ,...___lhe..ulll....... Caullf_IP. $'.eo .........,..,). s.. 'o.k.wfQrMt,ctdIlcn.IlrIflH'1M!IQn abDul:ngn~ym.ntcMhlul:. In)' ~Ir.d ,.,.ytnenlln ,...Wor. h.~h_...W det., .nd '"~"...",.,.". and ~.. ".rnNl'Ia.n.'~," PROMISE TO PAY. By livning tl'I,lI\taell_ GhA. you IlltNllJ lIMo twin. 01 t". Promi..ory HaIe.lId D~un ,nd' prom..1a "'Y UI the Total g( PIi,.m~" (ttItIlWm d FirnlI'lCl'Ch.rpplu. l/MI AIIIounlFNnCltd)/n monf/lly'~m,""" .llted ~., FN/'Ic' Ch.fII' lncIIId... non...rul'lll.bIltr.. d$150.00.nll ,"",,...twlllch hll. bMl'l cllfl::ullltflll in lIdY.ilnCtt.1 Ihe Cotrtract R." 01 25,"''' ptor.,..r 011 ~ .c:h-.1U1ed l,I"Pald biIIanc:e. Of! the ......'mplioll. tnt paym""'.... IrIIId. 0(1 Iml. DATE ON WHICH FINANCE CHARGES BEGIN. PAYMENT OATES. TIl,. ro.lI..... be _'I.IIIIm.r.d on ""-11ft. 1'011 ~.Ill'- c,*k for tile bill ptoc:wdt whi;h,.gU rRMM ",an Ill,. PrwrtlPOI)' NlIie .lId DillclDluI'H. FIn.ne. CI1I1J" llII btIg.n 011 tlJe de" fhI; c:1Mock II Cllhed, PREPAYMENT. 1f )'O\IllIIy ".,.'HI0... the rtltlll ,!)II,.m,nt 6INlll.... thl .rYICIl,ln! )'011_"" tIil ,...;Il,Icd lJy _r~ FlM:ncl C"'~I (btIt not the hrvlcl ch-"if) lllllwmin'" b)'ttItIRlAIo'7a1h1. LATE CHARGE. Iryou dOIl't p.y .",.p.,.mlllt1/1 1011.,. 1/1I,1'. 1l1ll,"gU """'0 PQ' 1.112% per /rIOI'lth on 1M .m(NI,lIO'1Il'1:1L11 (III~I to. 11.00 mll'Iinum ch.rg.J. 8AD CHECK CHARGE. W. d C"'1$I1 you II r.. 01 $20 r lIrI)' /II)'I'JMlnf chICk q f'ItIIrMd *-w. at Nl,IlDclent fllllIX or. on.rwtI.ll.tro~. YIIIl '8'" fIlilt _ m-r d~l,Io;tlhil~..ftvm.rrrorItIlIrpl)''''''''. FAILURE TO PAY. tfyoudPn11M1yanypllyrnlnt Of! tlrn'tll"lr_ IMIrrJllrlb; m.r bKomldL/l.t~ .nd...1I.hoI.It nottrlllt ral,l ~ b~ .wtt..... ml, IUl.fOI"ttM IotW amouM)'OIl P-....",. UIINrne4 F~1lt Cn.rve. YOI,I_lIId ,1I:eIv.' 10" IlIIy ptlpllld, Ind It))'OIJ.......o.,.., our "lfOllltMIIlltorn.y "'1, "t'" ltlD1nlJ" ill noI C1ur slllariedMlplo)'*l.lorllg.llpntc..aln". tocoa.ot IJII11 ~l'Iorl'Nlln on MCIIllIy. AlTERNATlVE DISPUTE RfSOLUTJON. TIITII, 01 tile ~tioIl ProvlIbn II pnwidld with Ihft PromlII'OI)' No" '/ld .oillcml,l,.. illIKlorpoI'IIlId h.,.,. by ,.,,""". CREDIT REPORTING AND CUSTOMER INFOR~TIOH PRACTICES. "1011 fI' to I'IIIIItIe t.m.1 of )'lIUl"Ctd obIlo.IJoon,' "".~ rwport ~ 011 1'01" cr.cIlt IWCCIl'd ""'1 bI,lIbm.tf1ld to. CrwdR RIPOfti'Isr ""Incy. YOll JQr10IlhIt till o.p.rtmenI cf Moler VllhldM (or)'OUl' ItII."IqIIlv.-rn ot .lICtlll.,.nmenl) ml)'........)'OUr ruld.~ .dd",.lolll, .h~i1~rwc:...'"IoIDcll.you. YOU~thllour.u,.t"tilllry,*"olll'l"lfIIYhterllottllph.,..c'" ~)'OIIMdoll,,,,,IIlIIIu.,.... ord.r 10 ~.ru.~ thlllllfllllr r1IlIlIr ..,.,1cII to yOU. For IfIOrllo'-41tior1 rtgm.." ""r prff"ll)' p...dlceI. pteael..., to tn.1IICktI-.1 Princr StalenIIIII. ITEMIZATION OF AMOUNT FINANCED. Th..mire MOllnt Fhan~ ("'own ~l will be 1"'1/1 dillcllr to l'OlI. III1IIII 11I5OIO-PM71..02240J ~71llllPA((l3fl)J""J floV'CCNLII flMUe.M Mr.!4JI)3"";n~1oII VERIFICATION I, Vida Bostic. unit manager for verify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge. information and belief, and that I am authorized to verify such Complaint on behalf of I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. t:~ Vida Bostic Dated: 0810412004 nr~ ~~ d~~5 ll:~~ ~~ MULL1LH HND MURRAY 4123817111 TO 8510400000009190 P.03/03 VERIFICA nON I, Ana Munoz, Recovery Specialist for Household Finance Consumer DiscountCompany verify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, infonnation and belief, and that I am authorized to verify such Complaim on behalf of Household FInance COnsumer Discount Company I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating 10 unsworn falsificalion to authorities. A~~y,;l~) \.0 Dated: Sept. 20, 2004 . \ ** TOTAL PAGE.03 ** 0~ 1\~ ....... w CI"l ~ f: 0 f'"" -c: :U ~ p=- i ,..1 E SHERIFF'S RETURN - REGULAR CASE NO: 2004-04772 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS HAGERICH DENNIS J AKA DENNIS H RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HAGERICH DENNIS J AKA DENNIS HAGERICH the DEFENDANT , at 2025:00 HOURS, on the 23rd day of September, 2004 at 6167 HAYMARKET WAY MECHANICSBURG, PA 17050 by handing to DENNIS J HAGERICH a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 8.14 .00 10.00 .00 36.14 r~#-J# R. Thomas Kline 09/24/2004 CHROMULAK & ASSOC Sworn and Subscribed to before By: ~d/ - Deputy Sheriff me this .6~ day of (]J~ ;L/JV<f A. D . ~_. Q~ ~~honotary ,~ .. THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-4772 - CIVIL Plaintiff, vs. TYPE OF PLEADING: Praecipe for Default Judgment DENNIS J. HAGERICH a/k/a DENNIS HAGERICH, TYPE OF CASE: Defendant. Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: Defendant's Address: 6167 HAYMARKET WAY MECHANICSBURG, P A 17050 CATHY ANN CHROMULAK, ESQUIRE PAID NO. 42067 SCOTT E. CRAWFORD, ESQUIRE PAID NO. 89570 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 Dated: OCTOBER 26, 2004 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. o ~:; ~t{: i8 " ~::;; ~ ..- .. " ~ = <:::;;:) J:.- o It ~ rn :!J :gFn t5? :'-I~ ..1: i O:n ~7 (') Om -I ;1;" _~o .< o ('? -f N co v ::It W .. <:::) <::) TO: PROTHONOTARY Please enter judgment by default against the within-named defendant, DENNIS J. HAGERICH alk/a DENNIS HAGERICH, for failure to file an Answer as follows: Amount claimed in Complaint: $5,600.75 Interest from 8/05/04 through 10/26/04: -0- Costs of Collection through 10/26/04: 500.64 TOTAL $6,101.39 With interest accruing on the total balance of $6.101.39 at the rate of6% per annum, together with additional costs of suit. BY~~ CATHY ANN CHROMULAK, ESQUIRE SCOTT E. CRAWFORD, ESQUIRE Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATION OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) ) ) SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared SCOTT E. CRAWFORD, ESQUIRE, attorney for and authorized representative 0 f plaintiff who, being duly s worn according to law, deposes and says t hat the defendant is not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed to defendant on OCTOBER 14, 2004 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attached copy, ~~ CATHY ANN CHROMULAK, ESQUIRE SCOTT E. CRAWFORD, ESQUIRE Sworn to and subscrib~ bEore me Thisc26? C7; dayof~ ,2004. ~A4-7~~~~'-~--~): . otaryPublic r . ,.... , '''',l.i,,,t, ....,l':.tl ,H )1] 'f Jonos N"'~;"1;V ,.'" " " "I "ugh, ~I~h..;,y Co'mty -, Ii" t<lon ExpIres Jan. ~ '.~. > THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . - ~ ':-::"'" ""'''::l~;,- ~ - - - ~ .." ~'.. ~ .. , #' ~ c::> J:" (;:) C'") -\ Q c" <:.::. -0\.'\; {~l' t ~ I 'i..";.,. ,>.;, ~~~i~ r-; 1;(-,,-: ,~.C) 'J'-c: -;7 :1 N OJ 'Q. :1,..,., t11 r: -Ora :0 s: qU. ~:g I" )-- :":f() t)n\ --I <."" Jb :<. -0 :J" c..;? Ci o IN THE ~OURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. 04-4772 CIVIL TERM DENNIS J. HAGERICH alkla DENNIS HAGERICH Defendant( s) ~- TO: DENNIS J, HAGERICH alkla DENNIS HAGERICH 6167 HAYMARKET WAY MECHANICSBURG, P A 17050 DA TE OF NOTICE: OCTOBER 14,2004 IMPORT ANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE 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 HA VE 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 ASSOCIA nON 2 LIBERTY AVENUE . CARLISLE, P A 17013 717-249-3166 or 800-990-9108 By: ~~~ CATHY ANN CHROMULAK, ESQ, SCOTT E. CRAWFORD, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, P A 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. . ,..., C:::-.:J 0 C) ...- -n D --I rJ :.c ..,., -1 rl1F I",' \:1 fTl CO :u? 80 -0 -Y" -r" :Jr:: ("5 :IJ ~''''O ..,,::: (..) (;rn ..-1 a )~ -< :'iJ 0 .< .'1) r-~ en !to s ." .... o 0.- 3 ~~ fA (I)~ ~~i~ ~ ...~ ;r , ~. g- i c ~ .... co co' .... 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ID a ~ 0 =!, !:!:~ ofd'" ~ DO::DO :e :e ~ -:r .... "-li!.g ::r:T.-+", s"V~.g "V l.i It "0 51 e: ~ a [~!!. 'g. -c"'"lll ::>... .... S ~ CD i' ..f. .~ '~l , .~ lli,~' , ~~ ,,~,:II ",,,! ! I:i~ '.t. Or.:r :::1:\ i q "~. ,'t .....:k ,..,', ""i ~, ;:~ 'ltGt ",,:to l~ r.n \i!'~" .: ,...~ 1\."""~ 'jt' .', '-'.J. ~ '.....if ; ,~~~~" if: ,-~ l'i4'~~~ ~>> "; ~~~<;'V~ ;:; U'\q.J, ,...;g o~"~.. . ':.&:. .~.. 'I...,..... ,I' .iI."I it; (~: ',\1, ,) :; '::) . :~~; "; ",...,) r.,.. g _,,1 ',,.1" lrrt: , ." 'I ..,il. .,~II 1, l-J 11 I..J'I ~;.... C Cl j' ~ ;,,,0.1 .. ",1 il ~ ....;n ::~) .. .:1, ~ ""..I ,j;:'" \',,:J , ' 0 '" 0 = c cO) -n :;:: .x:- 0 --I ~nF:; () :r: 'T! " :;~. '~" < -l rnp::: oK.,~' N -om ~) :06 co 0 -. -'0/'1" -0 +"'d C'" :l;: ~)o () (:')ffl C Y? ,-" S! 0 :~B 0 ,< THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-4772 - CIVIL Plaintiff, vs. DENNIS J. HAGERICH aJk/a DENNIS HAGERICH, Defendant. NOTICE OF ORDER. DECREE OR JUDGMENT TO: DENNIS J. HAGERICH alk/a DENNIS HAGERICH 6167 HAYMARKET WAY MECHANICSBURG, PA 17050 (X) Defendant You. are hereby no~ified tl#)'an ?rde~ ~cre~ or J~dFent was entered in the above captIOned proceedmg on L~t-~ J ~ L ~ () 6 '1' . ( ) A copy ofthe Order or Decree is enclosed, or (X) The judgment is as follows: $6.101.39 plus interest at the rate of 6% per annum and additional costs of suit. () /~_~L4 ' eJmty / THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. '~~ ........ Q ~~ -D " ~ ~ ~ -J o c ~ ..,>~ ' \ ~"-') t") ~~~ r- \..../ ~v i ) ~ , (.~ ~~ ~ f;: i::j ,'_10 .." :::::~... r. ~:f~ ~ -S) Ct '- ~ , ~ ~ ~ ,'~ ~ ,..., = <:::::> ..&- C) ,'"') -4 N <:0 -0 :l: '2 o o o 11 ._~ :r.: "'11 rnF- :39 ~:2q o_~ :T. -r, 0- 2m 8 ',::;" "~J :< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COUNTY, PENNSYL VANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No.04-4772-CIVIL Plaintiff, vs. TYPE OF PLEADING: DENNIS 1. HAGERICH a/k/a DENNIS HAGERICH, PRAECIPE FOR A WRIT OF EXECUTION Defendant, FILED ON BEHALF OF: and MEMBERS FIRST FEDERAL CREDIT UNION, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Garnishee. COUNSEL OF RECORD: Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 SCOTT E. CRAWFORD, ESQ. PAID NO. 89570 Garnishee's Address: 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 CHROMULAK & ASSOCIATES, L.L.c. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 (724) 916-2400 Defendant's Address: 6167 HAYMARKET WAY MECHANICS BURG, P A 17050 Date: NOVEMBER 5, 2004 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 COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No.04-4772-CIVIL Plaintiff, vs. DENNIS J. HAGERICH a/k/a DENNIS HAGERICH, Defendant, 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 County; 2, against DENNIS 1. HAGERICH a/k/a DENNIS HAGERICH, defendant, and 3. against MEMBERS FIRST FEDERAL CREDIT UNION, garnishee, 4. and index this writ a. against DENNIS 1. HAGERICH a/k/a DENNIS HAGERICH, 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 defendant in any accounts, individual and joint, personal and business. 5. Amount of Judgment Additional Interest to Date (Costs to be added) $6,101.39 $ 10.10 $ Pursuant to Writ of Execution And Service of Writ $6,111.49 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~~ SCOTT E, eRA WFORD, ESQ, Jr~ ~ (J ~ - ~ .....~ 1il ~~ ~ + w........ .IQ ~ . .:-O~ ~'1 ~ ....... \'-'1c~. ~tS 2 b ..tee C ~~ I 0 r () ~~ .... .... (\) ~ f{? " .... ... ... i ~ .... " ~ .... ... ... ;:rx:J~ ~ .... ..... -- .v S' . -.( .. ,/ I (' - I) ') , , \ ....... (') ,....." 0 c;::> (: C? -n ~ -.... -I ..r':~- :r:-"., 0 r(1r~ ....:: -;lrn I ;;:J(;.:' '-0 .,JO -~-j '., ....,. -.)'\ :t? \~:) ~~; -,,~.... -."*" <5 ,..,rn ( ) .,:::.~ p ....\:.",. :::~~ c;> &:.,~ - .....~ -c, 00 .., 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From DENNIS J. HAGERICH A/KIA DENNIS HAGERICH, 6167 HAYMARKET WAY, MECHANICSBURG, P A 17050 (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 MEMBERS 1 ST FEDERAL CREDIT UNION, 1166 WALNUT BOTTOM ROAD, CARLISLE, PA 17013 - SERVE INTERROGATORIES GARNISHEE(S) as follows: NO 04-4772 Civil CIVIL ACTION - LAW 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 he/she has been added as a garnishee and is enjoined as above stated. Amount Due $6,101.39 Interest $10.10 Atty's Comm % Atty Paid $118.64 Plaintiff Paid Date: NOVEMBER 9, 2004 L.L. $.50 Due Prothy $1.00 Other Costs (Seal) CURTIS R. LONG Prothon~ry '-!lY' to/U-.n -P.77zm/WJ./ Deputy REQUESTING PARTY: Name SCOTT E. CRAWFORD, ESQUIRE Address: CHROMULAK. & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 89570 SHERIFF'S RETURN - GARNISHEE CASE NO: 2004-04772 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS HAGERICH DENNIS J AKA DENNIS H And now SHANNON SHERTZER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:35 Hours, on the 12th day of November, 2004, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT HAGERICH DENNIS J AKA DENNIS HAGERICH , 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 true 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 So answers: ?""-~ '1'~ ~., R. Thomas Kline' Sheriff of Cumberland County 00/00/0000 -,-, this rle ...l~i day of iliu~ A.D. /'1 . ( ~. C fl<u.-u" J.P.'A Pro,*" notary , By )jLtiw/~ Deputy riff Sworn and subscribed to before me IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. 04-4772 vs. TYPE OF PLEADING: DENNIS J. HAGERICH alkJa DENNIS HAGERICH, Praecipe to Satisfy Judgment Against Garnishee ONLY Defendants, TYPE OF CASE: and Civil Action MEMBERS FIRST FEDERAL CREDIT UNION, FILED ON BEHALF OF: Garnishee. HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PAID NO. 42067 MELISSA A. SHENKEL, ESQ. PA ID NO. 91445 CHROMULAK & ASSOCIATES, L.L.C. Date: February 26, 2005 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. DENNIS J. HAGERICH alkla DENNIS HAGERICH, Defendant, and CIVIL DIVISION No. 04-4772 MEMBERS FIRST FEDERAL CREDIT UNION, Garnishee. PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please satisfy the judgment in this action against the above garnishee, MEMBERS FIRST FEDERAL CREDIT UNION and mark the docket accordingly. Sworn to and subscribed Before me this .;;J. /f day of ....5't.t.-. ,2005. ~d.'(l/1 ~ [)~D~ N t p::L"".cMMONWEALfH U" t't:I~I~5,LVANIA o ary u Notarial Seal Michelle L WoIota, NoIarI Public Cedi Twp., Washington County My Commlssloo E>pIres JUy 7, 2008 Member, Pennsylvania AssociatIon Of Notaries Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. ByA~ CATHY ANN CHROMULAK, ESQUIRE MELISSA A. SHENKEL, ESQUIRE 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. . ,. .. CERTIFICATE OF SERVICE I, Melissa A. Shenkel, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy the Judgment Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 28th day of February, 2005. MEMBERS FIRST FEDERAL CREDIT UNION CHARLES J. MCBREEN 5000 LOUISE DRIVE MECHANICSBURG, P A 17055 DENNIS J. HAGERICH a/k/a DENNIS HAGERICH 6167 HA YMARKET WAY MECHANICSBURG, P A 17050 ,M~ Melissa A. Shenkel, Esq. Dated: February 26, 2005 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ) D 0 Cj ~, .' ,,:;;',> ~ft \ r~: ,:.:";' .::./" \> -ni:.; =:c ,--..1 .y. lY 1J21.~ 7"" \\1 -;::V --. fl \ ~ ~ rv \, - () __.J }...l _,r'" - -- ....IJ .....{) 1 '-t? \> - --' , .. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. 04-4772 vs. TYPE OF PLEADING: DENNIS J. HAGERICH a1k1a DENNIS HAGERICH, Praecipe For Judgment Against Garnishee Defendant, TYPE OF CASE: and Civil Action MEMBERS FIRST FEDERAL CREDIT UNION, FILED ON BEHALF OF: Garnishee. HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. P A ill NO. 42067 MELISSA A. SHENKEL, ESQ. PA ill NO. 91445 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. ~'-J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-4772 Plaintiff, vs. DENNIS J. HAGERlCH a/k/a DENNIS HAGERICH, Defendant, and MEMBERS FIRST FEDERAL CREDIT UNION, Garnishee. TO: PROTHONOTARY Please enter judgment against Garnishee, MEMBERS FIRST FEDERAL CREDIT UNION, in the amount of$I,945.78 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 Plaintiffs judgment against the Defendant, interest and costs. Chromulak & Associates, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 By: athy Ann Chromulak, Esquire Melissa A. Shenkel, Esquire Attorneys for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL , . . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY. CIVIL DIVISION Plaintiff, No.04-4772-CIVIL vs. DENNIS J. HAGERICH a/k/a DENNIS HAGERICH, Defendant, and MEMBERS rIRST FEDERAL CREDiT UNION Garnishee. TO: MEMBERS FIRST FEDERAL CREDIT UNION ] 166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Y llU are rcquired 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. 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: jU,SPONSE: ~/O. 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 ofthe claim. RF~PONSE: [--- THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT , A I \ . . 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: 4';;.... / /~__' . 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: ~,.z...~,~-rs ,~-F .4 .,....,- ~.L' /ft".L<.,,,../</I. '1/>; f'YS': /'6 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: 7E'>. 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: /9'/& .B'n7...J 32,r :.5 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: /-/0. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. L-~.. \ ~ . . 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: 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: ~D. 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, slate the amount, and state the date of the transfer and the name and address of the transferee(s). RESPONSE: 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: ,/L-k) . I~THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~ ~ . . 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: Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.c. DATE: ~Oll~ 4 ~ ( By: ~'0~~ Cathy Ann Chromulak, Esq. Scott E. Crawford, Esq. 375 Southpointe Boulevard 4th Floor Canons burg, PAl 53 I 7 (724) 916-2400 THIS IS AN ATTEMPT TO , COLLECT A DEBT AND ANY I INFORMATION OBTAINED WILL 1_~E~_SED FOR THAT PURPOSE. - CERTIFICATE OF SERVICE I, Melissa A. Shenkel, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy ofthe foregoing Praecipe for Judgment Against Garnishee was served upon the following by First Class Mail, postage prepaid on this 10th day of February, 2005. MEMBERS FIRST FEDERAL CREDIT UNION CHARLES J. MCBREEN 5000 LOUISE DRIVE MECHANICSBURG, P A 17055 DENNIS J. HAGERICH alkla DENNIS HAGERICH 6l67HAYMARKETWAY MECHANICSBURG, PAl 7050 x~ Melissa A. Shenkel, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~ f{ >l '""l- " r." ~ ' , '." '. B ~l :".,::! ;"') J;i ....... ~ f' ~ .-) () ~ li'" ~ ........ ..c -.....c::: ..." C>- D , R: -I- r ( SHERIFF'S RETURN - GARNISHEE CASE NO: 2004-04772 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS HAGERICH DENNIS J AKA DENNIS H And now SHARON LANTZ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0010:20 Hours, on the 3rd day of June 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT HAGERICH DENNIS J AKA DENNIS HAGERICH , 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 LUANNE KYLE (ASST. MANAGER) 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 an!i)lf~ _ ~ rJ6-~~~ R. Thomas Kline Sheriff of Cumberland County 0010010000 Sworn and subscribed to before me this ~t- day of C},.. ,;'fJ7)"( A. D. (~k.- {J ~ ~ P 0 onotary , By ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. 04-4772-CNIL vs. TYPE OF PLEADING: DENNIS J. HAGERlCH a/k/a DENNIS HAGERlCH, Praecipe For Judgment Against Garnishee aud Defendant, TYPE OF CASE: MEMBERS FIRST FEDERAL CREDIT UNION, Civil Action Garnishee. FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PAID 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 HE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, vs. Plaintiff, CIVIL DIVISION No. 04-4772-CIVIL DENNIS J. HAGERICH alkJa DENNIS HAGERICH, and Defendant, MEMBERS FIRST FEDERAL CREDIT UNION, Garnishee. TO: PROTHONOTARY Please enter jUdgment against Garnishee, MEMBERS FIRST FEDERAL CREDIT UNION, in the amount of $389. 73 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 Plaintiffs jUdgment against the Defendant, interest and costs. Chromulak & Associates, L.L.c. 375 Southpointe Boulevard 4th F]oor Canonsburg,PA ]53]7 BY~~ Cathy'~'{nn Chromu]ak, Esquire Melissa A. Shenke], Esquire Attorneys for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL -.. ..--- --- -..-- --.----- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COUNTY, PENNSYL VANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION vs. Plaintiff, No.04-4772-CNIL DENNIS J. HAGERICH a!kIa DENNIS HAGERICH, Defendant, and MEMBERS FffiSTFEDERAL CREDIT UNION Garnishee. TO: MEMBERS FffiST FEDERAL CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, P A 17013 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. FffiST: At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to himlher on any negotiable or other written instrument, or did he/she claim that you owed himlher any money or that you were liable to himlher for any reason: INTERROGATORIES TO GARNISHEE RESPONSE: ~() 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: /-:/4-- THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT I A 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: ;;C5 FOURTH: If your response to the previous interrogatory was anything other than an unqualified negative, identity the property, and in the case of monetary assets, state the amount. RESPONSE: ,q~=<->~"r' -q /9<.- 9b :,_ ~5n 73 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: ,/t/Q SIXTH: If your response to the previous interrogatory was anything other than an unqualified negative, identity the property, and in the case of monetary assets, state the amount. RESPONSE: ..v /4- 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: .;'1../0 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: , ~4- 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: ./LIt) 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: ~ 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: ,/VV THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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: / ~ ~/,4- Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.c. DATE:51J (, I b') By04 X\ / Cathy Ann Chromulak, Esq. Melissa A. Shenkel, Esq. 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. I, Melissa A. Shenkel, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER CERTIFICATE OF SERVICE DISCOUNT COMPANY, 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 6th day of July, 2005. MEMBERS FIRST FEDERAL CREDIT UNION CHARLES J. MCBREEN 5000 LOUIS DRIVE P.O. BOX 40 MECHANICSBURG, PA 17055 DENNIS J. HAGERICH a/k/a DENNIS HAGERICH 6167 HA YMARKET WAY MECHANICS BURG, PAl 7050 ~~ Meh sa A. Shenkel, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~ D ~ ~ ~ ~ :-0 c - () ~ - ~ ~ 0 ...., ~ c = 0 <= ~ en -n \" <- :r-n ~ c - '\y r- rn- f""- -oh1 ~ ~ ~ :Joel I C) L _~:_~ C) ~ ~-=' :r: :1;, C :3:,'; q(-=j -L.. t~~ N tsrn Z ~--I --.., c:> ,!': -< ::D N .< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FmANCECONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No.04-4772-CIVIL vs. TYPE OF PLEADING: DENNIS J. HAGERICH alkJa DENNIS HAGERICH, Praecipe to Satisfy Judgment Against Garnishee ONLY Defendant, TYPE OF CASE: and Civil Action MEMEBERSF*STFEDERALCREDIT UNION, FILED ON BEHALF OF: Garnishee. HOUSEHOLD FmANCE CONSUMER DISCOUNT COMPANY Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA IV NO. 42067 MELISSA A. SHENKEL, ESQ. PA IV NO. 91445 CHROMULAK & ASSOCIATES, L.L.C. Date: September 9,2005 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL DIVISION No. 04-4772-CNIL vs. DENNIS 1. HAGERICH aIkIa DENNIS HAGERICH, Defendant, and MEMEBERS FIRST FEDERAL CREDIT UNION, Garnishee. PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE ONLY I TO PROTHONOTARY: Please satisfy the judgment in this action against the above garnishee, MEMEBERS FIRST FEDERAf. CREDIT UNION and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By: /VC ~ CATHY ANN'"CHROl\lULAK, ESQUIRE MELISSA A. SHENKEL, ESQUIRE Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscribed Before ~ this 9 day of '- r-' ,2005. . i)JoY<u THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1~f..ll.J - - Notary u "\I,,;ui<WEAU'H OF PENNSYLVANIA Notaf'ial Seal Michelle L. WoIo1a, Natm/ i'ublic Cedi Twp,. Washingt", ':''''''\y My CommiSSiOn FY~h~~ ,2008 lember. Penn~,_,,'j\fi!l1\,;.~ "',:':'U(;I~I!on Of Notaries CERTIFICATE OF SERVICE I, Melissa A. Shenkel, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy the Judgment Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 9th day of September, 2005. MEMEBERS FIRST FEDERAL CREDIT UNION CHARLES 1. MCBREEN 5000 LOUIS DRNE P.O. BOX 40 MECHANICSBURG, P A 17055 DENNIS 1. HAGERICH a/kJa DENNIS HAGERICH 6167 HA YMARKET WAY MECHANICSBURG, PA 17050 ~~'E~ Dated: September 9, 2005 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~ ~ );j l' !rl \i \\- 8 - t rI! ~ )J r- l; r' -F ;:~~ Sfi C.J' C'" (-I, :'\.,1 ~-. , (:? ~:,~ ~D --. :, .' ~.. '. - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, vs. DENNIS J. HAGERICH a/k/a DENNIS HAGERICH, Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION No. 04-4772 CIVIL Plaintiff, TYPE OF PLEADING: Praecipe to Satisfy Judgment TYPE OF CASE: Defendant. Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. P A ill NO. 42067 MICHAEL V. WORGUL, ESQ. PA ill NO. 93391 MAUREEN A. DOWD, ESQ. P A ill NO. 90549 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-4772 CIVIL Plaintiff, vs. DENNIS J. HAGERICH alk/a DENNIS HAGERICH Defendant. PRAECIPE TO SATISFY JUDGMENT TO PROTHONOTARY: Please satisfy the judgment against DENNIS J. HAGERICH alk/a DENNIS HAGERICH, at No. 04-4772, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. II / j / ~ V By: ,. .Ll/Cu~/~ CAtHY ANN CH OMULAK, ESQ. P A ill NO. 42067 MICHAEL V. WORGUL, ESQUIRE P A ill NO. 93391 MAUREEN A. DOWD, ESQUIRE P A ill NO. 90549 Attorneys for Plaintiff 375 Southpointe Boulevard 4 th Floor Canonsburg, PA 15317 Sworn to and subscJibed Befor~e this & day of 0Lf!-{ , 2005. M"rnbf' , "in Of Notaries THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Michael V. Worgul, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy Judgment was served upon the following by First Class Mail, postage prepaid on this 18 day of OCTOBER, 2005. DENNIS J. HAGERICH a/k/a DENNIS HAG ERICH 6167 HAYMARKET WAY MECHANICSBURG, P A 17050 L J2 () / / .iu I/j/ -. Michael V. Worgul, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .-l ("': 1,.'\ - ,~, in_'._I, r"_'J ,-') ------------ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL 3l:JJ!:/;AO 18.00 1.64 Advance Costs: 150.00 Sheriffs Costs 83.34 66.66 1.00 3.70 Refunded to Atty on 06/23/06 30.00 20.00 9.00 83.34 j ~ t.\-,olo~ <:> So Answers; ...c. , .J: -.} "V t-' ~~~~'> By C~l:LurJ; ~ ~\tu-~bQk_// SO :Z d 0 z: ,\V~'l ~OOl CJ .-' .:J.:JidJ S: iL ..,G 'J~ i " , . 5Hl1n ~Jl~ ~J,i r)) Ij :iJ 21 ((}I \ . {l.l en ~.., ~1./ If I~J7~nJ WRIT OJ<' EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-4772 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From DENNIS J. HAGERICH AlKJA DENNIS HAGERICH, 6167 HAYMARKET WAY, MECHANICSBURG, P A 17050 (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 MEMBERS FIRST FEDERAL CREDIT UNION, 1166 WALNUT BOTTOM ROAD, CARLISLE, PA 17013 - ALL MONIES DUE DEFENDANT 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,155.61 Interest TO DATE $244.62 L.L. Atty's Comm % Atty Paid $139.64 Plaintiff Paid Date: MAY 18, 2005 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) P'~th2 n 7lf./l/kLr- (.jJ~ o/"). I2..JL. 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 ID No. 91445 ".'- :::! ~-. ~'l R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale CertIfied Mail Postage Garnishee TOTAL '1 ':';J: 18.00 1.65 Advance Costs: 150.00 Sheriff's Costs 83.85 66.15 .50 1.00 3.70 Refunded to Atty on 06/23/06 30.00 20.00 9.00 83.85 Y' ~ ~ - .36-bl.., So Answers; ~~~~ R. Thomas Kline, Slieriff By (1o.uJ.. < ~- lS.\.Qu:bat./ o ...r; ..r. -l . I -> ~ : I Ll :E d b- AON ~OOl 'rJd 'AUWOJ CHiV-H:l38~n3 .:I.:HH3HS 3Hl .:10331.:1.:10 \.~ ~~1..f5Y'i ~, 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT NO 04-4772 Civil CIVIL ACTION - LAW COMPANY, Plaintiff (s) From DENNIS J. HAGERICH AlKJA DENNIS HAGERICH, 6167 HAYMARKET WAY, MECHANICSBURG, P A 17050 (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 MEMBERS 1ST FEDERAL CREDIT UNION, 1166 WALNUT BOTTOM ROAD, CARLISLE, PA 17013 - SERVE INTERROGATORIES GARt"ITSHEE(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 hirn/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $6,101.39 Interest $10.10 Arty's Comm % Arty Paid $118.64 Plaintiff Paid Date: NOVEMBER 9, 2004 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) PWIDonota.!Y E. '2!J:. ~~a-.f).- 'alA/V Deputy REQUESTING PARTY: Name SCOTT E. CRAWFORD, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ill No. 89570