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Home My WebLink About04-5010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04 - $'OlO el(.);lT~ Plaintiff, vs. TYPE OF PLEADING: Complaint NATALIE A. BROSIUS, TYPE OF CASE: Defendant. Civil Action FILED ON BEHALF OF: Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Defendant's Address: 104 SARAH COURT LEWISBERRY, PA 17339 CATHY ANN CHROMULAK, ESQ. PA ill NO. 42067 SCOTT E. CRAWFORD, ESQ. PAID NO, 89570 HEATHER C. TROXEL, ESQ. PA ill NO. 91848 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 9l6-2400 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 BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CNIL DNISION Vs. No. NATALIE A. BROIUS 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 AFFORDONE,GOTOOR 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 Plaintiff, CIVIL DIVISION No. 04- .s-CHC ~~c{ '-r~~ BENEFICIAL CONSUMER DISCOUNT COMPANY, vs. NATALIE A. BROSIUS, Defendant. 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. BENEFICIAL 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. NATALIE A. BROSIUS is an adult individual residing at ]04 SARAH COURT, LEWISBERRY,PA l7339. 3. On or about OCTOBER 4, 2002, 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 10, 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, including principal and interest, and owing by the Defendant is in the sum of SEVEN THOUSAND, SEVENTY SEVEN 13/100 ($7,077.13) DOLLARS as of JULY 22, 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 collection and reasonable attorney's fees. WHEREFORE, Plaintiff claims damages in the sum of SEVEN THOUSAND, SEVENTY SEVEN 13/100 ($7,077.13) DOLLARS, with interest thereon at the rate of23.99% from JULY 22, 2004, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC By: 5WJ-~wJ CATHY ANN CHROMULAK, ESQ. PA ill NO. 42067 SCOTT E. CRAWFORD, ESQ. P A ill NO. 89570 HEATHER C. TROXEL, ESQ. PA ill NO. 91848 Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg,PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page I of 4) LENDER (called "We", "Us", "Our") BENEFI(:IAL CONSUMER DISCOUNT COMPANY 4910 CARLISLE PIKE SUI TE 104 MECHANICSBURG PA 17050 . BORROWERS (called "You", ."Your") BROSIUS. NATALIE A SS# 179449013 104 SAR AH COUR T LEWISBERRY PA 17339' LOAN NO: 711714-26-507235 ..' ...~. ..01 AND OVER ANNUAl PE::g~.l"~1! PERCEtlfAGE . . RAre 2.000" _ 24,000 % cRE:DIT LIMIT OA.TE OP' LOAN ON PORTION OF AVERA~E ~AllY B"u.NCE I 5500 10/04/02 ~li.~.. '-~ ~"....~ . ~:,/ j:. ~ ~'.~ ~. ~ .. . INITiAL ANNUAL SUBSEQUENT ANNUAl FEE 'EO ' , .00 . 50.00 .;' 5m--:;rnli~:A -t~~ ~'t . [ .. 1i-~ ~~- ",' .........__ ~_ ~' ,t - In this Agreement, "you", "your" and "Borrower". mean the customer(s) who signs this Agreement. "We", "us", and "our" refer to Lender. This Agreement covers the terms and conditions of your Personal Credit Line Account. We want you to understand how your Personal Credit Line Account works, Read this carefully, ask us any questions, and if you agree to be bound by this Agreemel}t, sign below. If'more than one person signs" each will be responsible for repaying all sums advanced under thi's Agreement. . , '. Your Credit Line Account is a revolving line of credit extended to you and secured as deScribed below. You can obtain funds from your Personal Credit Line Account (up to your credit limit) directly from U$,or by using the special checks we supply to you. You may pay your total unpaid balance at any time or in installments. . . " t', ..~. ,", -t.. ., . REQUIRED INSURANCE~' You must obt.ain insurance f~r term or J0811 coveting security for this loaD. agreement as .iDdice:~d'.by the word "YI;;S. below, naming us as Lou Payee: , Physic~.I damage insurance on vehicle listed under "Security" Bbo'C'e, if "Y" appears: 'under- "Insured," Y au may oblllin BDY required irisural2cc from anyonCl you choose. . NOTICE: SEE THE FOLLOWING PAGES FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO OfSPlfTE ;~~~":"~,. I!!!!!.~!!!!!!'I P~~rfS JIJI~~!~ "",,,,; - -' PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 2 of 4) A vailable Credit: You may obtain funds directly from us or through your special checks up to your available credit. Each check must be wrItten for at least $100.00, Your available credit is your credit limit (shown on page one) less the total unpaid balance, including Finance Charges, of your Account. If you make loan payments by check, we will adjust your available credit seven days after we receive your check to allow for check clearing, If you request funda in an amount that would cause you to exceed your available credit, we are not obligated to honor your request. If we do lend you an amount oVer your available credit, you agree to pay us that excess amount, plus Finance Charges, immediately. Promise to Pay; You promise to pay Lender: (a) amounts borrowed under this Agreement; (b) Finance Charges, Admllustratlve Charges (the late charge and bad check charge) and other charges provided in this Agreement; (c) credit insurance charges, if any; (d) collection costs permitted by applicable law, including reasonable attorneys' fees; and (e) amounts in excess of your credit limit that we may lend you, plus Finance Charges. Payments: You may repay your entire outstanding balance at any time without penalty, You may not use your special checks to pay any amounts due under this Agreement. Because the Finance Charge is computed each day, you will contact us regarding the exact payoff amount for the day you intend to make full payment. If you do not pay the entire unpaid balance on your Account at once, you agree to pay at least the minimum payment shown On your monthly statement, Payments wiII be applied as follows; First, to any accrued but unpaid Finance Charges; Second, to any unpaid Administrative Charges (the late charge and bad check charge); Third, to any unpaid credit insurance charges; and Fourth, to the outstanding balance of your Account. Any part of your monthly payment to be applied to amounts borrowed on your Account will be applied to the amounts borrowed under your Personal Credit Line Account in the order in which the amounts were borrowed. Any part of your monthly payment to be applied to Finance Charges will be applied in the same manner. Minimum Monthly Payment: The Minimum Monthly Payment for any billing cycle will be the greater of (J) the greater 01 $D or the Payment Amount (as described below) plus any Administrative Charges and credit insurance charges, rounded to the nearest $1; or (2) the Finance Charges due for the billing cycle plus any Administrative Charges and crodit insurance charges; or (3) the amount of the Annual Fee assessed to your Account, In each instance the Minimum Monthly Payment will be adjusted to include any unpaid amounts due from previous billing cycles. The Payment Amount depends on the monthly periodic rate applicable to your Account, and is calculated as follows: Monthly Periodic Rate Payment Amount through 1.33% 1.43% of Account Balance over 1.33% through 1,45% 1.55% 01 Account Balance over ],45% through 1.57% ].67% of Account Balance over 1.57% through 1,70% 1.80% of Account Balance over 1.70% through 1.83% 1.93% of Account Balance over 1.83% through 1.95% 2.00% of Account Balance over 1.95% 2.15% of Account Balance Finance Charges: This is the interest charged on the balance of your Account during each billing cycle. The Finance Charge IS calculated Irom the date that each advance, check or charge is posted to your Account. The Finance Charge is computed by multiplying the average daily balance in your Account in each billing cycle times the monthly periodic rate stated on page one. The average daily balance is determined by totaling all daily unpaid balances in each billing cycle and dividing the total by the number 01 days in that cycle (but not less than thirty). A daily unpaid balance is the amount owed each day, excluding any unpaid Finance Charge, Administrative Charges, and credit insurance charges for prior billing cycl es. Annual Fee: You agree to pay an Annual Fee as stated on page one for participation in this revolving credit plan. The Initial Annual Fee is stated on page one and is due and payable on the date that your Account is established, and the subsequent Annual Fee stated on page one is due and payable on the same day of each subsequent year. You agree that this fee may be charged to your Account balance. Bad Check Charge: If you pay by a check which is returned for any reason, you agree to pay a bad check charge of $20. Late Charge: 1f you do not pay any required Minimum Monthly Payment within ]5 days after it is due, you agree to pay a late charge 01 10% of the Minimum Monthly Payment due or $20, whichever is greater (excluding any unpaid late charges and amounts due from prior billing cycles). NOTICE: SEE THE FOLLOWING PAGES FOR AOOITIONAL PROVISIONS ANO IMPORTANT' INFORMATION REGARDING YOUR RIGHTS To DISPlJTE BllUNG ERRORS. 03-01-00 F NRE 1IIIIIImmm 1U1~~I~IIIOOIIIIIMlllillllllml R 11111I1111100 Imll~ 1Ii1~IIilllllllll~11111I 0011111111111111111 PA055352 ~BI63S67S0D93RlA9000PA0553520..BRosrus . ORIGINAL , PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 3 of 4) Other Charges: You agree to pay any amounts actually incurred by Lender for services rendered in connection with the Personal Credit Line Account for fees paid to public officials in connection with perfecting, recording, releasing or satisfying a security interest in the security. You agree that these fees may be charged to your ACCOunt balance, Exchange of Information: You understand that from time to time we may receive credit information concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a regular basis, we obtain related to your Account, including but not limited to credit reports and insurance informatinn, with any of our affiliated corporations, subsidiaries or other third parties, The uses of this information may include an inquiry to determine if you qualify for additional offers of credit. You also authorize US to share any information regarding your Account with any of our affiliated corporations, subsidiaries or other third parties. You may prohibit the sharing of such information (except for the sharing of information about transactions or experiences between us and you) by sending a written request which contains your full name, Social Security Number and Address to us at P,O. Box 1547, Chesapeake, VA 23320, If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent : of such department) may release your residence address to us, should it become necessary to locate you. You agree that our supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the quality of our service to you. Termination and Changes in the Agreement: We can terminate your right to obtain additional advances or change the terms of this Agreement, including increasing the rate of Finance Charge at any time. Prior written notice will be given to you when required by applicable law unless you consent to the change berore that time, Changes may apply to both new and outstanding balances unless prohibited-by applicable law. Default and Cancellation of Agreement: We have the right to require you to pay your entire balance plus all other accrued but unpaid charges lmmedtately and/or to cancel your credit privileges under this Agreement because of: (a) failure to make any payments in full when due under this Agreement; (b) frequent overdrawing of y~ur line of credit; (c) failure to supply us with any information requested; (d) supplying us with misleading, false, incomplete or incorrect information; (e) breaking any of the promises, terms or conditions that are contained in this Agreement; (f) the filing of a banliruptcy petition by or against you; (g) the death of any borrower who signs this Agreement: or (h) the sale or transfer of any interest in the property securing this agreement (this includes the creation of a subordinate lien), After default, you will pay our court costs, reasonable attorney fees (if attorney is not our salaried employee), and other collection costs related to the default, if not prohibited by applicable law: Any balance outstanding under this Agreement when the credit limit is terminated will continue to accrue interest at the contract rate until paid in full. " ';".J:' .... . ).>....~ ,l".' f . This notice contains important imformation about your rights and Lender's responsibilities under the Pair Credit Billing Act. YOUR BILLING RIGHTS KEEP THIS NOTICE FOR FUTURE USE Notify Lender In Case of Errors or Questions About Your Bill ;' -J .. \.- ~. ~ If you think your bi!! is wrong, or if you need mOre information about a transaction on your bill, write Lender on a separate sheet at the address listed on your bill after the words: 'Send your billing error notice to: (Lender's. name and address).. Write to Lender as soon as possible. Lender must hear from you no later than 60 days,after Lender sent you the first bill on which the error or problem appeared. You can telephone Lender, but doing so will.fl.otpr,es,eryeyour rights. /', .. I . ..... '- . NOTICE: SEE THE FOLLOWING PAGE FOR AODIT'ONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BIlliNG ERRORS. 03-01-00 F NRE lIIliIIW~lIlmlllill~I~IOOI ~~I ~IIIIII il~I~limlll~II~lmllilIl~m' IIIDllllm~11I m~~i~11 PAOS5353 kBl635675D093RLA9000PAOS63630kMBRosrus . ORIGINAL- PERSONAL CKEDIT LINE ACCOUNT AGREEMEN'I \!'age 4 of 4) In your letter, give Lender the following information: . Your name and account num ber. . The dollar amount of the suspected error. . Describe the error and explain, if you can, why you believe tbere is an error. If you need more information, describe the item you are not sure about. Your Rights and Lender's Responsibilities After Lender Receives Your Written Notice Lender must acknowledge your letter within 30 days, unless Lender has corrected the error by then, Within 90 days, Lender must either correct the error or explain why Lender believes t!>e bill was correct, After Lender receives your letter, Lender cannot try to collect any amount you question, or report you as delinquent. Lender can continue to bill you for the amount you question, including finance charges, and Lender can apply any unpaid amount against your credit limit, You do not have to poy any questioned amount while Lender is investigating, but you are still obligated to poy the parts of your bill that are not in question, If Lender finds that Lender made a mistake on your bill, you will not have to pay any finance charges related to any questioned amount. If Lender did not make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, Lender will send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount that Lender thinks you owe, Lender may report you as delinquent. However, if Lender's explanation does not satisfy you and you write to Lender within ten days telling Lender that you still refuse to pay, Lender must tell anyone Lender reports you to that you have a question about your bill. And, Lender must tell you the name of anyone Lender reported you to. Lender must tell anyone Lender reports you to that the matter has been settled between us when it finally is. If Lender doesn't follow these rules, Lender can't colleet the first $50 of the questioned amount, even if your bill was correet Alternative Dispute Resolution and Other Riders: The terms of the Arbitration Agreement and any other Riders SIgned as part of tlus Joan transactIOn are incorporated mto this Agreement by reference, Applicable Law: The terms and conditions of this Agreement will be governed by the provisions of tbe Pennsylvania Consumer v,scount Company Act, Chapter 7, Sections 6201 through 6221, Purdon's Pennsylvania Statutes Annotated, particularly Section 6217.1. Before signing this Agreement, you have read and received this Agreement and the Federal Truth-In-Lending disclosures contained in it, You, the customer(s) signing below, agree to observe the terms and conditions of this Agreement. This Agreement is entered under the applicable provisions of Federal law and the Pennsylvania Consumer Discount Company Act, b~~~~J!~ (SEAL) (SEAL) Customer Signature Date: 10-4- O~ Date: Witnes~ ~() (SEAL) (SEAL) 03-01-00 Rl F NRE PA05S364 I~I~"~I" H1lill~"mIIOOlll"II~~ 1~11~llilllm~II~~lmll~lIi""I!IIi"mJl '!II00lml~II'li 1111 "BI6356750Q93RlASOOOPA0563640"BROSIUS , ORIGINl\l II LOAN CLOSING STATEMENT REVOL VING LOAN VOUCHER CREDITOR BENEFICIAL CONSUMER DISCOUNT COMPANY 4910 CARLJSLE PIKE SUITE 104 MECHANICSBURG PA 17050 BORROWERS BROSIUS. NATALIE A 104 SARAH COURT LEWISBERRY PA 17339 LOAN NO: 711114-26-507235 Borrowers agree to and direct the disbursements and Advance indicated below. If any estimated amount shown below varies from the actual amount paid, Borrowers agree to the disbursement of the actual amount and a corresponding change to the Advance shown below. Borrowers agree that this Advance is made under Borrowers' Revolving Loan Agreement (account number shown above.) TO: 71171400539506M.........,.......,....,.................................... $ CASH OR CHECK TO BORROWER... . . . . . . . . . . . . . . . . . . . . . ..' . . . . . . . . . . . . . . . . . . . . , , . . . . . $ TOTAL AOVANCE(S)...,.. .., .. . . .. ... ., ... .. . .. .. .. .. . .. .. .. ..... . .. . .. . ., ... . '" . $ WITNESS ~~ (of tf (()'2-- ATE BORROWERS: hWL(. Q &<U;1~ '2D-99 Vo~cher 1~lmW~HlllllllllmmlllllflflHMlllmlffl~flf~wnlllfllDllllI ~a'635675va93RlV90DOPA1319110~.BROS'US . OfU G I NAL 4206.79 1293.21 5500.00 j\~ Gb PAI379tl L 7d P ~ ~ 1'",- ~ , -- w crt ~ "Q D- C> ~ r D ~ :E: -r r-l , ''', G ,\ ~.. ,) () t.).) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 04-5010 Plaintiff, vs. TYPE OF PLEADING: Praecipe to Reinstate Complaint NATALIE A. BROSIUS, TYPE OF CASE: Defendant. Civil Action FILED ON BEHALF OF: Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Defendant's Address: 801 SILVERSPRINGS ROAD MECHANICSBURG, P A 17055 CATHY ANN CHROMULAK, ESQ. P A ill NO. 42067 SCOTT E. CRAWFORD, ESQ. P A ill NO. 89570 CHROMULAK & ASSOCIATES, L.L.c. 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. (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. 04-5010 vs. NATALIE A. BROSIUS, Defendant. PRAECIPE TO REINSTATE COMJPLAINT TO THE PROTHONOTARY: Please reinstate the complaint in the above-captioned action, at 04-5010 and mark the docket accordingly. BY At.oo-~~ CATHY ANN CHROMULAK, ESQ. SCOTT E. CRAWFORD, ESQ. 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. , THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, No. 04-5010 CNIL TERM Plaintiff, TYPE OF PLEADING: vs. Praecipe for Default Judgment NATALIE A. BROSIUS, TYPE OF CASE: Defendant. Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: Defendant's Address: 801 SIL VERSPRINGS ROAD MECHANICSBURG, P A 17055 CATHY ANN CHROMULAK, ESQUIRE PAID NO. 42067 MELISSA A. SHENKEL, ESQUIRE PAID NO. 91445 ALAN G. STAHL, ESQUIRE PAID NO. 85437 CHROMULAK & ASSOCIATES, L.L.c. 375 Southpointe Boulevard 4th Floor Canonsburg, P A 15317 Dated: DECEMBER 28, 2004 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. TO: PROTHONOTARY Please enter judgment by default against the within-named defendant, NATALIE A. BROSIUS, for failure to file an Answer as follows: Amount claimed in Complaint: $7,077.13 Interest from 7/23/04 through 12/28/04: 605.76 Costs of Collection through 12/28/04: 650.89 TOTAL $8,333.78 With interest accruing on the total balance of $8,333.78 at the rate of 6% per annum, together with additional costs of suit. ~:~~ESQUIRE MELISSA A. SHENKEL, ESQUIRE ALAN G. STAHL, ESQUIRE Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATION OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY ) ) ) SS: Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared MELISSA A. SHENKEL, 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 her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed to defendant on DECEMBER 15, 2004 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attac d copy. ~^'- _ C c~w;LAK, ESQUIRE MELISSA A. SHENKEL, ESQUIRE ALAN G. STAHL, ESQUIRE Sworn to and subscribed before me This ~ ~ day of~ ,2004. ~~ otary Public t/ \~o~Q:i3.; .::..' :";:. . - ,7 :;,ardner Jones, No'.<c'.- , '='i\tsburgh, Alk'9.heny C(y.'~" , ':'\ :::>:;.mmission Exp!res Jan ,___i. ,......'---:.: ~.:>...l"~.,!.v~r"\ia ,t\~st'y;;?~;^ , ~, 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 BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. 04-5010 NATALIE A. BROSIUS Defendant(s) TO: NATALIE A. BROSIUS 801 SIL VERSPRINGS ROAD MECHANICSBURG, P A 17055 DATE OF NOTICE: DECEMBER 15, 2004 IMPORTANT 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 HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 or (800) 990-9108 By: C~~ESQ. MELISSA A. SHENKEL, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. \l ,.... ... -L en ~~.~ (J1 ? c.;;: r-r::::~ c (1)3 CD ~~ "'4 0. 0 " ~; .. ii. ~ g 0' .. 2 ~ iO ll:l .". i1~ --C::. 2 !!!. .1' :z , ~c eg. .,,~ Ss. -." 0.. :112 2.. ." ~ 3 II .. ~a; ~" .~ 0/ ~ ~ .. ;a <Il () i } ~ '.:t:> 0- . i :;} '\~ ~)l \ 'i #c", 121 \~ . 'fI ~ .~ii ~~i-'~~"~ '\'l ~-L."i~i CIlo."'~.~!:T III .. If" 3'12. 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Bf;i ".. c ~~: ~ ~~; (, ,1 ~~! 2:: -,..; -< r--..) c::::~ c:.:> C.J'1 C- > :sz: o -n -~ m-n Tlh, :i.JO () l.. .:.\C) -,- 'T' r):d ,:.io-p (j,n :;; ,< I W ::-:-- -~ I..D f..)1 .- SHERIFF'S RETURN - REGULAR CASE NO: 2004-05010 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS BROSIUS NATALIE A KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BROSIUS NATALIE A the DEFENDANT , at 1958:00 HOURS, on the 24th day of November, 2004 at 801 SILVER SPRINGS ROAD MECHANICSBURG, PA 17055 by handing to NATALIE BROSIUS 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 Service Affidavit Surcharge So Answers: 18.00 8,14 .00 10,00 ,00 36.14 r~~/2-~ . R. Thomas Kline 11/29/2004 CHROMULAK & ASSOC Sworn and Subscribed to before me this t- -::: day of C)"",._-' A'j d-iJtJ~ A, D, ~ Q '/n,;p,., JJ~' Prothonotary , , By: )ffy t2fiv\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA BENEFICIAL CONSUMER DISCOUNT CQMPANY, CIVIL DIVISION: PLAINTIFF, No. 04-5010 CIVIL TERM TYPE OF PLEADING: VS. NATALIE A. BROSIUS, MOTION TO COMPEL ANSWERS TO INTERROGATORIES IN Am OF EXECUTION DEFENDANT. FILED ON BEHALF OF: BENEFICL\L CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Dated: lIJ-z."Z-16 CATHY ANN CHROMULAK P A ill No. 42067 MELISSAA. SHENKEL PA ID No, 91445 CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTEBoULEVARD 41liFLOOR CANONSBURG, P A 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA BENEFICIAL CONSUMER DISCOUNT ) COMPANY, ) ) ) PLAINTIFF, ) ) VS. ) ) NATALIE A. BROSIUS, ) ) DEFENDANT. ) CIVIL DIVISION: No. 04-5010 CNIL TERM MOTION TO COMPEL ANSWERS TO INTERROGATORIES IN AID OF EXECUTION AND NOW, comes the Plaintiff, BENEFICIAL CONSUMER DISCOUNT COMPANY, by and through its attorneys, Chromulak & Associates, L.L.C., atld moves this Court for an Order, pursuant to Pa.R.Civ.P. 40l9, to compel the Defendant, NATALIE A. BROSIUS, to respond to interrogatories and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant was entered on January 3, 2005 in the sum of$8,333.78. 2. Plaintiff served interrogatories upon Defendant, via first class mail on March 30, 2005. A true and correct copy of the interrogatories are attached hereto as Exhibit "A" and incorporated herein by reference. 3. Pursuant to Pa.R.Civ.P. 4006 (a)(2), Defendant's responses to the interrogatories were due within thirty (30) days after they had been served. 4. A demand letter was sent via first class mail on May 9, 2005, A true and correct copy of the demand letter is attached hereto as Exhibit "B" and ineorporated herein by reference. 5. As of the date of this Motion, no responses have been received from the Defendant. 6. Plaintiff requires an Order pursuant to Pa.R.Civ.P. 4019(a)(1)(i) compelling Defendant to answer the interrogatories. WHEREFORE, Plaintiff respectfully requests the Cowt to approve the proposed Order annexed hereto. ~ <Z5i ~ CATHY ANN CHROMULAK PAID 42067 MELISSA A SHENKEL PAID 91445 CHROMULAK& AsSOCIATES, L.L.c. 375 SOlJTHI~OINTEBOULEVARD 4TH FLOOR CANONSBURG, PENNSYLVANIA 15317 (724) 916-2400 (734) 916-2411 (FACSIMILE) DATED: (,lz-z../~~ 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, PLAINTIFF, VS, NATALIEA. BROSIUS, DEFENDANT, s March 30, 2005 You are Hereby Notified to Plead to the Enclosed Interrogatories Within 30 Days From Service Hereof or a Default JUM~AgainstYOu, .(ttorney for Plaintiff rrvn nrVI:~: No. 04-5010 CIVU.. TERM TVl'F OF PI.F A mNe;: INTERROGATORIES IN AID OF EXECUTION DIRECTED TO DEFENDANTNATALIEA. BROSIUS ](f, .Fn ON RFH A T F OF PI ,4 TNTTFF: BENEFICIAL CONSUMER DISCOUNT COMPANY rorTNSFT, OF RFCORn' CATIIY ANN CHROMULAK PA ill No. 42067 MELISSA A, SHENKEL PA ID No. 91445 CHROMULAK & ASSOCIATES LLC 375 Southpointe Blvd. 4th Floor Canonsburg" PA 15317 (724) 916-2400 EXHIBIT I A. IN 'DiE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL Y ANIA DEFENDANT. ) ) ) ) ) ) ) ) ) ) Clvn . nIVISImi: BENEFICIAL CONSUMER DISCOUNT COMPANY, PLAINTIFF, No. 04-5010 CNIL TERM YS. NATALIE A. BROSIUS, INTERROGATORIES IN AID OF EXECUTION DIRECTED TO DEFENDANT NATALIE A. BROSIUS , TO: Natalie A.Brosius 801 Old Silversprings Road Mechanicsburg, PA 17055 AND NOW COMES, Plaintiff, Beneficial Consumer Discount Company, by their attorneys, Chromulak & Associates LLC, and herewith files and serves on Defendant the following Interrogatories, to be answered by Defendant under oath within thirty ("0) (laY" in accordance with 1 the Rules of Discovery of the Pennsylvania Rules of Civil Procedure. (Space has been provided, but if such space is insufficient for a complete Answer, please complete Answer on a separate sheet and attach hereto.) 1. What is your full legal name? ANSWER: 2. What is YQur current address? ANSWER: 3. Are you employed? Who is your employer? List the name, address, and phone number of each employer. ANSWER: 4. What is ydur monthly income? List both gross and net for each employer. ANSWER: 5. Do you have any other sources of income? If yes, describe all sources of additional income I in detail. ANSWER: 6. Are you ~arried? ANSWER: 7. Do you own or have any interest in any land/real estaLte? If yes, briefly describe the land/real estate (i.e. address) and the ownership interest you possess. ANSWER: 2 8. If anyone is assisting you ill answenng these interrogatories, state his or her name, relationship to you, and address. ANSWER: 9. What savings, checking and money market accounts do you own or have any interest in? ANSWER: F;n~n(':htl Tn~titlltlnn A~(':nllnt No rllrrf~nt R~l;::m(':p. a. b. c. d. ! 10. What Individual Retirement Account (IRA) do you own? ANSWER: Fin~n(':i~ 1 Tnditnt1nn A (':(':cmnt No rllTTf':nt R~hn(':p. a. 11. Do you own or have interest in a safety deposit box? If yes, describe the location and the \ . contents of the safety depOSIt box. ANSWER: 3 l2. Do you belong to a credit union or other work related savings plan? If yes, describe. ANSWER: l3. What stocks, shares, bonds, notes and shares in a mutual funds do you own or have an interest in? ANSWER: Typ~ (i P; ~h~rp., hnnii~ ptr.) N::Imp. of ~()rpnr:l1inn (:nrrp.nf H~l~nr:p: a. b. 14. Does any individual, partnership, or corporation owe you money? If yes, provide details of I the debt. ANSWER: 15. Do you O\'iIl life insurance? If yes, list the insurance company and policy number. ANSWER: I , 4 16. What televisions, stereos, VCRs, camcorders, caml~ras or other electronic/camera equipment do you have in interest in? ANSWER: 17. What household furnishings do you have an interest in? ANSWER: 18, What jewelry do you own or have an interest in? ANSWER: 19. What frrealms do you own or have an interest in? ANSWER: 20. What coins, stamps or other collectibles do you own or have an interest in? ANSWER: ,i 5 21. What other personal property (not previously described) do you own or have an interest in? ANSWER: 22. What other assets (not previously described) do you have an interest in? ANSWER: 23. If, in the preceding six years, you have transferred any assets (real property, personal property), to any person, and/or, if you have given any gift valued at more than $250.00, of any asset, including money, to any person; set forth, in detail, a descliption of the property, the type of transaction, the date of occurrence and the name and address of the transferee or recipient. ANSWER: 24. . Is any of your property rented to, leased to or otherwise in possession of a third person? If so, state full descIjiption of the property; the name and address of the person, firm, or other entity , who has possessiqJ1 of the property; the circumstances and reason why the property is in possession of the third persop; the consideration or payment received by you; the name and address of the person who receives the rents or other consideration on behalf of you. ANSWER: 6 25. State whether or not you own or have any rights in any motor vehicles. Include a full description of each such motor vehicle including color, mode'!, title number, serial number and registration plate number. Also show the name or names in whieh each motor vehicle is registered, tbe present value of each motor vehicle and their present location and place of regular storage, garaging or parking. State also whether or not there are any encumbrances on those motor vehicles and if so, the name and address of the encumbrance holder, tbe date of the encumbrance, the original amount of that encumbrance, the present balance of the encumbrance and the transaction which gave rise to the existence of the encumbrance. If not owned, state the extent of your rights in and to such vehicles. ANSWER: 7 26. What money have you received within the last sixty days from any source, and what have you done with it? Identify sources. ANSWER: 27. List all monthly expenses and the amounts paid thereto. ltlclude all utilities, rent/mortgage, credit cards, and other loans, and any other monthly payments made by you, ANSWER: ;,1 i1~ PAID42~7 MELISSA A. SHENKEL PAID 91445 CHROMULAK & ASSOCIATES LLC 375 SOUTHPOINTEBLVD 4TH FLOOR CANONSBURG,PA 15317 (724) 916-2400 (724) 916-2411 MARCH 30, 2005 8 CKRTTFlC":A TK OF ~KRVIC":K I, Melissa A. Shenkel, counsel for Beneficial Consumer Discount Company, hereby certify that a true and correct copy of tbe foregoing Interrogatories in Aid of Execution were served via U.S. First Class Mail on the following, this~ day of )1~>=., 2005: Natalie A. Brosius 801 Old Silversprings Road Mechanicsburg, PA 17055 ~iSS~nkel' Esquire CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TI1 FLOOR CANONS BURG, PENNSYLVANIA 15317 TELEPHONE (724) 916-2400 FACSIMILE (724) 916-241l Melissa A. Shenkel Attorney- At-Law Direct Dial: (724) 916-2418 mshenkel@chromulak.com May 9,2005 Ms. Natalie Broius 80l Old Silversprings Road Mechanicsburg, ~A 17055 RE: Beneficial Consumer Discount Company vs. Natalie Brosius No. 04-5010 CIVIL TERM; CumberlandCounty, Pennsylvania Dear Ms. Brosius: On March 30, 2005, my office sent a set of Interrogatories to you that were to be answered and returned within thirty (30) days. As of the date of this letter, my office has received no response. I have enclosed a copy of the interrogatories that were previously mailed to you. Please return the answered interrogatories to my office no later than May 19, 2005. Ifmy office does not receive these papers from you by the date indicated, we may proceed with further legal action against you. Very truly yours, AS~ MELISSA A. SHENKEL MAS/drnr \. TIHIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT I B IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANJA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION: PLAlNTIFF, No. 04-5010 CIVIL TERM VS. TYPE OF PLEADING: NATALIE A. BROSIUS, MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL ANSWERS TO INTERROGATORIES IN AID OF EXECUTION DEFENDANT. FiLED ON BEHALF OF: BENEFICV\L CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Dated: c., / -Z-'Z-- { 0<> CATHY ANNCHROMULAK PA ill No. 42067 MEUSSA A. SHENKEL P A ill No. 91445 CHROMULAK& AsSOCIATES, L.L.C. 375 SouTHlmINTEBOULEVARD 4TH FLOOR CANONSBURG,PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANJA BENEFICIAL CONSUMER DISCOUNT ) COMPANY, ) ) ) PLAINTIFF, ) ) VS. ) ) NATALIE A. BROSIUS, ) ) DEFENDANT. ) CIVIL DIVISION: No. 04-5010 CIVIL TERM MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL ANSWERS TO INTERROGATORIES IN AID OF EXECUTION FACTS AND INTRODUCTION Plaintiff commenced this action alleging non-payment of a loan agreement entered into by the parties. Judgment for Plaintiff and against Defendant was entered on January 3, 2005 in the amount of $8,333.78. Plaintiff served interrogatories upon Defendant, via fIrst class mail on March 30, 2005. Pursuant to Pa.R.Civ.P. 4006 (a)(2), Defendant's responses to the interrogatories were due within thirty (30) days after they had been served. A demand letter was sent via first class mail on May 9, 2005. As of the date of this Motion, no responses have been received from the Defendant. Plaintiff requires an Order pursuant to Pa.R.Civ.P, 40l9(a)(1)(i) compelling Defendant to answer the interrogatories. ARGUMENT Rule 4019( a)(l )(i) of the Pennsylvania Rules of Civil Procedure provides that a "Court may, on motion, make an appropriate order if a party fails to serve answers, sufficient answers or objections to written interrogatories under Rule 4005". Rule 4005 requires that the answering party serve answers to written interrogatories with in thirty days of the service of the interrogatories. As the interrogatories were served to the Defendant on or about March 30, 2005 and as the Defendant has, to date, failed to answer the interrogatories, this Court should enter the proposed Order attached to Plaintiff's Motion to Compel. CONCLUSION For the reasons set forth above, this Court should ente:r the proposed Order attached to Plaintiff's Motion to Compel Answers to Interrogatories, and wmpel Defendant to answer said interrogatories. L!j 6~ CATHY ANN CHROMULAK PAID 42067 MEUSSAA. SHENKEL PA ID 91445 CHROMULAK & AsSOCIATES, L.L.C. 375 SOUTHPOINTEBOULEVARD 4TH FLOOR CANONSBURG, PENNSYLVANIA l5317 (724) 916-2400 (734) 916-2411 (FACSIMILE) DATED: f.41~"t-lri CERTIFICATE OF SERVICE I, Melissa A. Shenkel, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Motion to Compel Answers to Interrogatories In Aid of Execution and Memorandum of Law was served, via United States First Class mail, postage prepaid, on the following, this ~tay of '~.A..--L-- ,2005: NATALIE A. BROSIUS 801 SILVERSPRINGS ROAD MECHANICSBURG, PA 17055 ~L~ Melissa A. Shenkel ...., ~ (') = ~ C ,;;;.n ~:n <'" <- c: x ::y; ;! ~~ C. W C> ~- ~T1 ..", 90 ::;:: -'-en '"1 r:--.' 8 c - 1> ~ Cl ~ 0 BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff v. NATALIE A. BROSIUS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-5010 CIVIL TERM ORDER OF COURT AND NOW, this ih day of July, 2005, upon consideration of Plaintiffs Motion To Compel Answers to Interrogatories in Aid of Execution, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of the date of this order. ~ Ann Chromulak, Esq. Melissa A. Shenkel, Esq. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Attorneys for Plaintiff J%talie A. Brosius 801 Silver Springs Road Mechanicsburg, PA 17055 Defendant, pro se :rc BY THE COURT, J. VW\!\/I\lAS;\:f-.Hd ,\,! ~,10{"\'~, .:'C)i,'\U....:J ......'1..'. '..\'.,1 9 I :2 Hd g- lnr SOOl Atfvl0i\'CHJ.OtJd :Jill .::10 38H:iCHTJlI:l if p