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.
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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":
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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 **
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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.
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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
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" "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.
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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.
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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.
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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,
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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 ~, .'
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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
.,....,-
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'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.
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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: / ~
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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.
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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.
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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
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Michael V. Worgul, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
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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~
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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
".'-
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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./
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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