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HomeMy WebLinkAbout04-4775IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, vs. JACK A. BENDER and KATHIE BENDER Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 7S SPRUCE LANE CARLISLE, PA 17013 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Plaintiff, CIVIL DIVISION TYPE OF PLEADING: Complaint TYFE OF CASE: Defendants. Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 HEATHER C. TROXEL, ESQ. PA ID NO. 91848 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 4`" Floor Canonsburg, PA 15317 (724)916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. // No. 04 - 4'7'75 Clc., ~ l~ E.IZ~/1 JACK A. BENDER KATHIE BENDER 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, PENNSYLVANIA HOUSEHOLD FINANCE CIVIL DIVISION CONSUMER DISCOUNT ~y COMPANY, No OI{ -~ [ /~ ~tc~~(,,~£1Lv~ Plaintiff, vs. JACK A. BENDER and KATHIE BENDER, Defendants. COMPLAINT AND NOW COMES, the Plaintiff, BENEFICIAL 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. JACK A. BENDER and KATHIE BENDER are adult individuals residing at 75 SPRUCE LANE, CARLISLE, PA 17013. 3. On or about JUNE 29, 1993, Defendants entered into a written Loan Agreement with the Plaintiff, as evidence by the Affidavit of Lost/Destroyed Instrument attached hereto as "Exhibit A" and incorporated herein. 4. Pursuant to the Loan Agreement with the Defendants, Plaintiff advanced funds to the Defendants. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5. Defendants are in default under the terms and conditions of the aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about APRIL 30, 2004. 6. Pursuant to the terms of the Loan Agreement, Plaintiff has the right to require payment of the entire amount owed upon default. The total amount due, including principal and interest, and owing by the Defendants is in the sum of NINE THOUSAND, EIGHT HUNDRED SIXTY 14/100($9,860.14) DOLLARS as of AUGUST 4, 2004. 7. Numerous demands have been made upon the Defendants by Plaintiff, but the Defendants have failed or refused to pay. Pursuant to the Loan Agreement, Plaintiff is entitled to recover costs of collection and reasonable attomey's fees. WHEREFORE, Plaintiff claims damages in the sum of NINE THOUSAND, EIGHT HUNDRED SLYTY 14/100($9,860.14) DOLLARS, with interest thereon at the rate of 13.9 from AUGUST 4, 2004, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associat , LLC Bye CATHY ANN CHROMULAK, ESQ. PA ID NO.42067 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 HEATHER C. TROXEL, ESQ. PA ID NO. 91848 Attorneys for Plaintiff 375 Southpointe Boulevard 4`~ Floor Canonsburg, PA 15317 TNIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. STATE OF Pennsylvania IN THE DTSTRICT COURT FOR THE JUDICIAL DISTRICT Household Finance Consumer Discount Company Plaintiff vs. Case No.: Defendant(s) Jack A Bender and Kathie Bender ACCT # 71171517500818 AFFIDAVIT OF LOST/DESTROYED INSTRUMENT IDA COOPERYOUNG, being sworn deposes and says: 1. That he/she is the Legal Specialist at Household Finance Consumer Discount Company and makes this Affidavit on their behalf. 2. That this Affidavit is mad e on information and belief of the affiant after thorough review of all records of Household Finance Consumer Discount Company pertinent to the Defendant's account. 3. That the original contract in this matter has been destroyed or lost. 4. That if originals or duplicates are discovered, they will be submitted to the Court for cancell tion. ~~ ~' _ ~~ h ~~~ Subscribed and savor Ito bef re t J/ day of r-`G,~._~, r,,<RR,, J N~ otary Public - a icia Brown me on 2004. State of ILLINOIS County of DUPAGE My commission expires on: May 21, 2006 OFFICIAL SEAL PA7RICIA BROWN NOTRNY PU9110~ ~~ ~ I W WOIS p,~ISiE8fr21.2008 W{/,N Nw~n` ~ PLA1N't7FF'3 ~LXM(8~T 04/13/2004 22:56 17249162411 CHR~MUTAK ASSOCIATES PAGE 02102 VERIFICATION Angela Davis, 5r. Clerk for Household Finance Consumer Discount Company Deposes and says subject to the penalties of 18 Pa C.S. Section 4904 relating to unswottl falsification to authorities, that the facts set forth is the forgoing Complaint are true and con-ect to the beat of her knowledge, information and beliet: Angela Davis ~ ~ ~ #k ~I- C SHERIFF'S RETURN - REGULAR CASE NO: 2004-04775 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERhAND HOUSEHOLD FINANCI's CONSUMER VS BENDER JACK A ET AL RONALD KERR Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BENDER JACK A the DEFENDANT at 1951:00 HOURS, on the 24th day of September, 2004 at 7S SPRUCE LANE CARLISLE, PA 17013 by handing to KATHIE BENDER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.44 Affidavit .00 Surcharge 10.00 .00 32.44 Sworn and Subscribed to before me this ,~~ day of 7 ~ C~iQi~c..~. oZ-eh A . D . n h ~~ oPt to h ota ry ' So Answers: R. Thomas Kline 09/28/2004 CHROMULAK & ASSOC By : 1~--~-~ /L----- Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE N0: 2004-04'775 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERhAATD HOUSEHOLD FINANCE CONSUMER VS BENDER JACK A ET AL RONALD KERR Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BENDER KATHIE the DEFENDANT at 1951:00 HOURS, on the 24th day of September, 2004 at 7S SPRUCE LANE CARLISLE, PA 17013 by handing to KATHIE BENDER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me/~t~his ~ day of ~ 7Yt-[.CQw '~j P thonotary So Answers: ~~~~~ R. Thomas Kline 09/28/2004 CHROMULAK & ASSOC By : /~/ ~ / DeputyDeputy Sheriff Il'~ THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. JACK A. BENDER AND KATHIE BENDER, Defendants. Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendants' Address: 7S SPRUCE LANE CARLISLE PA 17013 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 04-4775 TYPE OF PLEADING: Praecipe For Entry Of Consent To Judgment TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 SCOTT E. CRAWFORD, ESQ. PA ID NO. 89570 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 •IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 04-4775 Plaintiff, vs. JACK A. BENDER AND KATHIE BENDER, Defendants. PRAECIPE FOR ENTRY OF CONSENT TO JUDGMENT TO PROTHONOTARY: Please enter judgment in favor of Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY and against Defendants, JACK A. BENDER AND KATHIE BENDER, in the amount of TEN THOUSAND SIX HUNDRED THIRTY-EIGHT AND 02/100 ($10,638.02), with interest thereon at the legal rate of 6% from SEPTEMBER 30, 2004, as evidenced by the Consent to Judgment attached hereto as Exhibit A. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By; 3t~. cC~-~~ Scott E. Crawford, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN~THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 04-4775 Vs. Plaintiff, JACK A. BENDER AND KATHIE BENDER Defendants. CONSENT TO JUDGMENT AND NOW, to wit, this ~ day of ~/C;~ ~~~ ~'~' , 2004, with the consent of all parties and their respective counsel, it is agreed as follows: Judgment shall be and is hereby entered against Defendants JACK A. BENDER AND KATHIE BENDER in the amount of TEN THOUSAND SIX HUNDRED THIRTY- EIGHT AND 02/100 ($10,638.02) DOLLARS plus interest on the unpaid balance at the rate of 6% per annum commencing on SEPTEMBER 30, 2004. 2. Defendants JACK A. BENDER AND KATHIE BENDER agree to make an initial payment of TWO HUNDRED FIFTY AND 00/100 ($250.00) to Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY and monthly payments thereafter in the amount of ONE HUNDRED FORTY-THREE AND 00/100 ($143.00) DOLLARS on or before the 20TH day of each month for NINTY-FOUR (94) consecutive months, until the entire debt owing Plaintiff is paid in full. The first payment shall be due on or before OCTOBER 8, 2004. 3. Payments shall be sent to Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY in care of CHROMULAK & ASSOCIATES, L.L.C., 375 Southpointe Boulevard; 4th Floor, Canonsburg, PA 15317, or any other address Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY may later designate. EXHIBIT 4. Defendants JACK A. BENDER AND KATHIE BENDER have induced Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, and Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY agrees to forbear in the enforcement of its rights against them so long as Defendants JACK A. BENDER AND KATHIE BENDER make timely payments. If Defendants JACK A. BENDER AND KATHIE BENDER fail to make timely payments, then Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY may institute or take all steps necessary, appropriate or helpful to collect the judgment, represented hereby, together with the Plaintiff's costs of collection and attorneys fees therefore. AND NOW, on the date written above, the parties set forth their hands and seals as follows: ~~ fitness ~ ACK A. B NDER KATHIE BENDER ~~~~~i~--P~-Q. Scott E. Crawford, Attorney for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Scott E. Crawford, Esquire, counsel for Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing PRAECIPE FOR ENTRY OF CONSENT TO JUDGMENT was served upon the United States First Class Mail osta a re aid on this ~~~ da of following by p g p p _ Y (~C , 2004: JACK A. BENDER 7S SPRUCE LANE CARLISLE PA 17013 KATHIE BENDER 7S SPRUCE LANE CARLISLE PA 17013 ~~;~~. Scott E. Crawford, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~~ ~ -0 ~~ o ~) c =, t"~ E.~ ~fz ~. ~`"' ~'- ,~. `_ ~ , y ~ t': __.~ 1 N ~.~ .c' e:~.', .o;; CJl ~:r C1) .~." ` c~ -ra ....~ ~~=~ T~ _~ ,""1 ".a.3 ~t "~ 1 . -, C, =';:7 C ~ ~'n ," ''7 -.:' ~IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 04-4775 Vs. Plaintiff, JACK A. BENDER AND KATHIE BENDER Defendants. CONSENT TO JUDGMENT AND NOW, to wit, this ~ day of ~~ U )e r , 2004, with the consent of all parties and their respective counsel, it is agreed as follows: 1. Judgment shall be and is hereby entered against Defendants JACK A. BENDER AND KATHIE BENDER in the amount of TEN THOUSAND SIX HUNDRED THIRTY- EIGHT AND 02/100 ($10,638.02) DOLLARS plus interest on the unpaid balance at the rate of 6% per annum commencing on SEPTEMBER 30, 2004. 2. Defendants JACK A. BENDER AND KATHIE BENDER agree to make an initial payment of TWO HUNDRED FIFTY AND 00/100 ($250.00) to Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY and monthly payments thereafter in the amount of ONE HUNDRED FORTY-THREE AND 00/100 ($143.00) DOLLARS on or before the 20TH day of each month for NINTY-FOUR (94) consecutive months, until the entire debt owing Plaintiff is paid in full. The first payment shall be due on or before OCTOBE1t 8, 2004. 3. Payments shall be sent to Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY in care of CHROMULAK & ASSOCIATES, L.L.C., 375 Southpointe Boulevard, 4th Floor, Canonsburg, PA 15317, or any other address Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY may later designate. 4. Defendants JACK A. BENDER AND KATHIE BENDER have induced Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, and Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY agrees to forbear in the enforcement of its rights against them so long as Defendants JACK A. BENDER AND KATHIE BENDER make timely payments. If Defendants JACK A. BENDER AND KATHIE BENDER fail to make timely payments, then Plaintiff HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY may institute or take all steps necessary, appropriate or helpful to collect the judgment, represented hereby, together with the Plaintiff's costs of collection and attorneys fees therefore. AND NOW, on the date written above, the parties set forth their hands and seals as follows: ~~'~~ ~ fitness ~~ ~~~ ACK A. B NDER KATHIE BENDER ~~~~. Scott E. Crawford, Attorney for Plaintiff THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. SHERIFF'S RETURN - GARNISHEE CASE N0: 2004-04775 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS BENDER JACK A ET AL And now CPL. MICHAEL BARRICK ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:50 Hours, on the 15th day of July 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , BENDER JACK A in the hands, possession, or control of the within named Garnishee AMERICHOICE FEDERAL CREDIT UNION 20 SPORTING GREEN MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to KELLY SMITH (HEAD TELLER) , 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 .00 Service .00 Affidavit .00 Surcharge .00 nn UU So a er~~ / ? R. Thomas Kline Sheriff of Cumberland County 03/18/2005 Sworn and subscribed to before me this ~j'~}d day of (2,,p," i;i A.D. ~ ~ 1 _ _.. ~,ee~~.~ P o onotary ' By ~~~ ~ Deputy SYf~riff SHERIFF'S RETURN - GARNISHEE CASE NO: 2004-04775 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS BENDER JACK A ET AL And now MICHAEL BARRICK ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:50 Hours, on the 15th day of July 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , BENDER KATH hands, possession, or control of the within named Garnishee AMERICHOICE FEDERAL CREDIT UNION SPORTING GREEN DRIVE MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to KELLY SMITH (HEAD TELLER) in the 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: So ~~y,~~~~~,~2 Docketing .00 ' Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County ,00 .00 07/lE3 Sworn and subscribed/too before me this ~9~ day of (.,,LA ~O o-~ A . Dnn. t'°y- C.i, / ~1~ P o onotary ' /ZOOS ' -~ B Deputy heriff IN THE COURT OF COMMON PLEA5 OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-4775 Plaintiff, vs. JACK A. BENDER and KATHIE BENDER, TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION Defendants, and AMERICHOICE FEDERAL CREDIT UNION, Garnishee. Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 7S SPRUCE LANE CARLISLE, PA 17013 Garnishee's Address: 20 SPORTING GREEN DRIVE MECHANICSBURG, PA 17050 Date: JULY 6, 2005 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MELISSA A. SHENKEL, ESQ. PA ID NO. 91445 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4`h Floor Canonsburg, PA 15317 (724)916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL DIVISION No. 04-4775 vs. JACK A. BENDER and KATIIIE BENDER, Defendants, and AMERICHOICE FEDERAL CREDIT UNION, Garnishee. PRAECIPE FOR WRIT OF EXECUTION TO: The Prothonotary Please issue a Writ of Execution in the above matter, l . directed to the Sheriff of .CUMBERLAND County; 2. against JACK A. BENDER and KATHIE BENDER, defendants, and 3. against AMERICHOICE FEDERAL CREDIT UNION, garnishee, 4: and index this writ a. against JACK A. BENDER and KATHIE BENDER, defendants, and b, against AMERICHOICE FEDERAL CREDIT UNION, garnishee, and any property of the defendants in the name of Garnishee: Said Writ of Execution is pursuant to aB monies due defendant in anv accounts, individual and joint, personal and business. 5. Amount of Judgment Additional Interest to Date Less Payments Made (Costs to be added) $10,638.02 -d93Pd0~. $ 116.34 $(1,255.00) Pursuant to Writ of Execution And Service of Writ r THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. $9,499.36 y v~ MELISSA A. SHENKEL, ESQ. ~~ ~ ~ d .~ ;~ c ~~ h -~s kl' w ~ i- ~ ~ - - = - ~- ~ r _ _ _ ;- *~ n c ° a ' . , ~ ~ ~ O'~3 : G --- s ` ~ ~ . ~ .l y - ~. ~:di i' i ~~, °_ =` WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-4775 Civil COUNTY OF CUMBERLAND) 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 JACK A. BENDER AND KATHIE BENDER, 7S SPRUCE LANE, CARLISLE, PA 17013 (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 AMERICHOICE FEDERAL CREDIT UNION, 20 SPORTING GREEN DRIVE, MECHANICSBURG, PA 17050 -INTERROGATORIES -PURSUANT TO 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $9,383.02 L.L. $.50 Interest $116.34 Atty's Comm % Due Prothy $1.00 Atty Paid $130.44 Other Costs Plaintiff Paid Date: JULY 11, 2005 CURTIS R. LONG Prothonotary ~'~f~ (Seal) ~$y' ~ D o r~ / '/ //Oil Deputy REQUESTING PARTY: Name MELISSA A. SHENKEL, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4rn FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 91445 IN THE COURT OF COMMON PLEA5 OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL D1:VISION vs. JACK A. BENDER and KATHIE BENDER, and AMERICHOICE FEDERAL CREDIT UNION, Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. No. 04-47'75 TYPE OF' PLEADING: Praecipe to Discontinue Against G:rnishee ONLY TYPE OF CASE: Defendant, Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER Garnishee. DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MELISSA A. SHENKEL, ESQ. PA ID N0.91445 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724)916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CIVIL DIVISION CONSUMER DISCOUNT COMPANY, No. 04-4'~775 Plaintiff, vs. JACK A. BENDER and KATHIE BENDER, Defendant, and AMERICHOICE FEDERAL CREDIT UNION, Garnishee. PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please discontinue this action against the above garnishee, AMERICHOICE FEDERAL CREDIT UNION and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. CATHY ANN CHROMULAK, ESQUIRE MELISSA A, SHENKEL. ESQUIRE Attorneys for Plaintiff 375 Southpointe Boulevazd 4`h Floor Canonsburg, PA 15:517 Sworn to and subsc 'bed Befo me this ~~_day of ~ , 2005. THIS IS AN ATTEMPT TO EN Y COLLECT A DEBT AND ANY bta, ryPubGc INFORMATION OBTAINED WILL ashkgtonc^,ounty BEi USED FOR THAT PURPOSE. E~ires Jody 7, 2008 CERTIFICATE OF SERV ICE I, Melissa A. Shenkel, Esquire, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby certify that a true and conf;ct copy of the foregoing Praecipe to Discontinue Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 26 day of JULY, 2005. AMERICHOICE FEDERAL CREDIT UNION 20 SPORTING GREEN DRIVE MECHANICSBURG, PA 17050 JACK A. BENDER and KATHIE BENDER 7S SPRUCE LANE CARLISLE, PA 17013 ~~..~- Melissa A. Shenkel, Esq. NNIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE IJSED FOR THAT PURPOSE. ~ ~~~ ~r r !' ~ ~ ~ , ~ r~ _ J (~ ~ __ O -' r,i to R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Docketing 18.00 Poundage 1.53 Advertising Law Library .50 Prothonotary 1.00 Mileage 8.00 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 78.03 So Answers; this b '`~ day of 2006 A.D. c.~ prot onotazy Advance Costs: 150.00 Sheriff's Costs 78.03 71.97 Refunded to Atty on 01{18106 O Sworn and Subscribed to l~'ore iris r R. 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AND you, the Prothonotary of said Court, upon receipt by you of your costs, are hereby authorized and empowered, in the name and stead of the Plaintiff, to enter full satisfaction upon the record of said Lien as fully and effectually, to all intents and purposes, as we could were we present in person to do so; and for so doing, this shall be your sufficient warrant of authority. IN TESTIMONY WHEREOF, there is hereunto affixed the Seal of the Department of Labor and Industry, Commonwealth of Pennsylvania, this 17 TH day of NOVEMBER 2006. ACCOUNT NO. 21-23470 AD NO. 313114 CUMBERLAND COUNTY, PENNSYLVANIA ~~.,e, /r SEAN F, y G Deputy Chief Cdunsel for Employment Security d o~ w~ a~ H '~ °~~ °v z wo o~ U F ~ ~ T 6' c~ _WG,. C ~' -cs ice: ~r~~: ~~:. ~.. ~ ` `~ --• ~ ~ o N ~ A ~ N w Z ~ w . ~ A p , + ~` ~ ~ z. `~ ~ z ~ o r a ° ~- w 0 ~ N ~/ W o~,~o ~ H 'x w ~ a©~~ , ~w r ~~ o O H p"~., ~` d ~p ~ f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. JACK A. BENDER and KATHIE BENDER, Defendant. CIVIL DIVISION: No. 04-4775 TYPE OF PLEADING: Praecipe to Satisfy Judgment TYPE OF CASE: Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID N0.42067 MAUREEN A. DOWD, ESQ. PA ID NO.90549 BETH ARNOLD HOWELL, ESQ. PA ID NO.203606 CHRISTINE A. SAUNDERS, ESQ. PA ID NO.203373 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4`h 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. JACK A. BENDER and KATHIE BENDER, Defendant. CIVIL DIVISION: No. 04-4775 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please satisfy the judgment against JACK A. BENDER and KATHIE BENDER, at No. 04-4775, and mark the docket accordingly. Sworn to and subscribed Before me this _~day of , 2007. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By: ~1~G~~~~- CATHY ANN CHRO LAK, ESQ. MAUREEN A. DOWD, ESQ. BETH ARNOLD HOWELL, ESQ. CHRISTINE A. SAUNDERS, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 ~• Notary Pu is C=OMiv10NWEALTH OF PENNSY~~'µfd:,- Notaria!Seal ;eatfier i_. Hatfield, Notary Puy: CecilTwp., Wastrington County cJ~y Commission Exx.7res June 29, 2btG THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 7 r CERTIFICATE OF SERVICE I, 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 4th day of May, 2007. JACK A. BENDER KATHIE BENDER 7-S SPRUCE LANE CARLISLE, PA 17013 ,_.~ . /~ ~ ~~ ,~ ~1~~ Cathy Ann Chromu ,Esq. Maureen A. Dowd, Esq. Beth Arnold Howell, Esq. Christine A. Saunders, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. C':~ ~.~ ~-- c~ ~.,, r~ _ --.. _ _~Z ~ r ~~„ ~ rr~ - -,-... `, ..1 ~,-~ - G,.) r; `:z ••