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Home My WebLink About05-3159 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. Of:; - .$/ S"'f Cw~L '-rEIL~ Plaintiff, vs. TYPE OF PLEADING: Complaint MICHAEL J. LEONE and KELLEY J. LEONE TYPE OF CASE: Defendants. Civil Action FILED ON BEHALF OF: Plaintiffs Address: 2700 Sanders Road Prospect Heights, II., 60070 BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Defendant's Address: 1110 FLORIBUNDA DRNE MECHANICSBURG. P A 17055 CATHY ANN CHROMULAK, ESQ. PA ill NO. 42067 MELISSA A. SHENKEL, ESQ. PA ill NO. 91445 CHROMULAK & ASSOCIATES, LLC 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 BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. MICHAEL J. LEONE and KELLEY J. LEONE 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, P A 17013 717-249-3166 OR 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THA T PURPOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. DS -::~I S 9 eLV~l ~~ vs. MICHAEL J. LEONE and KELLEY J. LEONE, 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. 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. MICHAEL J. LEONE and KELLEY J. LEONE are adult individuals residing at I I 10 FLORlBUNDA DRIVE, MECHANICSBURG, PA 17055. 3. On or about OCTOBER 10, 2002, Defendants 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 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 SEPTEMBER 19, 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 THIRTEEN THOUSAND, SEVEN HUNDRED SEVENTY EIGHT 5/100 ($13,778.05) DOLLARS as of MAY 10,2005. 7. Numerous demands have been made upon the Defendants by Plaintiff, but the Defendants have 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 Sunl of THIRTEEN THOUSAND, SEVEN HUNDRED SEVENTY EIGHT 5/100 ($13,778.05) DOLLARS, with interest thereon at the rate of24% from MAY 10, 2005, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC /"'" By: /'\ i)'\.~---- CATHY ANN CHROMULAK, ESQ. PAID NO. 42067 MELISSA A. SHENKEL, ESQ. PA ID NO. 91445 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. Physical damage insuranco on vchiclo listed under '"Security" above. if .V'" appears under '"Insured.. You mey obtain any required insurance from anyone you choose. NOnCE: SEE lHE FOLLOWING PAGES FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. 03-01-00 F NRE 1111111111111 EXHIBIT DUllllllm PA056361 PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page I of 4) LENDER (called "We", "lJs", "Our") BENEFICIAL CONSUMER DISCOUNT COMPANY 4910 CARLISLE PIKE SUITE 104 MECHANICSBURG PA 11050 BORROWERS (called "You", "Your") LEONE. MICHAEL J sSt 358621145 LEONE. KELLEY J SSt 115485913 1110 FLORI BUNDA DR MECHANICSBURG PA 11055 LOAN NO: 111114-26-501292 ON ,.CATlON 0' AVfRACiE DAIL., BALANCE MONTHLY PERIODIC "ATE ANIIJAI. I'ERCfNTAIlE RATE: 2.000 %_ 24.000 % CREDIT LIMIT DATe 0' LOAN - . INITIAL ANNUAL SUeSEQU FEE 9000 10/10/02 .01 AND OVER ANNUAL - % In this Agreement, "you", "your" and "Borrower" mean the customer(s) who signs this Agreement. "We", "us", and "our" refer to Lender. This Agreemenl 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 Agreement, sign below. If more than one person signs, each will be responsible for repaying all sums advanced under this 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 us or by using the special checks we supply to you. You may pay your total unpaid balance at any time or in installments. REQUIRED INSURANCE. You must Dbu.D insunncc for term of loan covering security for this loan agreement as indicated by the word .YES. below. naming us IS Loss Payee: 'L93B16151N96RLA9000PA0563610" I "A" ORIGIW,L 'L93816157N96RtA900OPAOS63620"LEONE , ORIGiNAl PA056362 PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 2 of 4) Available 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 SIOO.OO. 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 dRys after we receive your check to allow for check clearing. If you request runds 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, AdmInistratIve l;harges (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 dRy 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 Btlltement. Payments will 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 (I) the greater of ~~ or the t'ayment Amount (as described below) plus any Administrative Charges and credit insurance charges, rounded to the nearest SI; or (2) the Finance Charges due for the billing cycle plus any Administrative Charges and credit insurance charges; or (3) the amount of the Annual Fee asse<lS-o 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 I:lalance . over 1.33% through 1.45% 1.55% of Account Balance over 1.45% through 1.57% 1.67% 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 Accounl 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 l;harge IS calculatoo from the dRle that each advance, check or charge is posted 10 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 dRily unpaid halances in each billing cycle and dividing the total by the number or dRys in that cycle (but not less than thirty). A dRily unpaid balance is the amount owed each dRy, excluding any unpaid Finance Charge, Administrative Charges, and credit insurance charges for prior billing cycles. Annual Fee: You agree to pay an Annual Fee as Btllted on page one for participation in this revolving credit plan. The lrotlal Annual Fee is Ststed on page one and is due and payable on the dRte that your Account is established, and the subsequent Annual Fee stated on page one is due and payable on the $Bme day of each subsequent year. You agree that this fee may be charged to your Account b8lance. Bad Check Charge: If you pay by a check which is returned for any reason, you agree to pay a bad check: charge of S20. Latc Charge: If you do not pay any required Minimum MontWy Payment within IS dRys after it is due, you agree to pay a late charge of 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 AOOmONAl PROVISIONS AND IMPORTAHT INfORMATlON REGARDING VOUR RIGHTS TO DISPUTE BIlliNG ERRORS. 03-01-00 f NRE 1.1111111181111111111111111111111111 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. Esehange 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 information, 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 tbe sharing of such information (except for the sbaring of information about transactions or experiences between us and you) by sending a written request wbich contains your full name, Social Security Number and Address to us at P.O. Box 1547, Cbesapeake. V A 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 evaluale 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, IncludlOg increasing the rate of Finance Charge at any time. Prior written notice will be given to you..hen reqUired by applicable law unless you consent to tbe change before that time. Changes may apply to botb 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 unplUG! charges ImmedIately and/or to cancel your credit privileges under this Agreement because of: (a) failure to make any payments in full when due under this Agree~ent; (b) frequent overdrawing of your 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, lerms or conditions that are contained in this Agreement; (f) the filing of a bankruptcy 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. YOUR BILLING RIGHTS KEEP THIS NOTICE FOR FUTURE US E This notice contaios important imformation about your rights and Lender's responsibilities under the Fair Credit Billing Act. Notify Lender In Case of Errors or Questions About Your Bill If you think your bill is wrong, or if you need more information about a transaction on your bill, wrile Lender on a separate sheet at the address listed on your bill afler 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 lateT than 60 daY~ after Lender sent you the first bill on which the error or problem appearCd. Y 09. can lelephone Lender, but doing sq will not presen.e y'!ur rights. '. ~ NOTIcE: SEE THE FOLLOWING PAGE FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGAROING VOUR RIGHTS TO DISPi.m: BI~UNG ERRORS. 03-01-00 F NRE PA05S363 I.IIIIIIIIIIRIIIIIIIIIIIIIIIIIIIIIIIIII "L938167S7N96RlA900aPAOS6363Q"LEONE . oRIGINAL . ' PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 4 of 4) . . In your letter, give Lender the following information: . Your name and account number. . The dollar amount of the suspected error. . . Describe the error and explain, if you can, why you believe there 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 tile error by then. Within 90 days. Lender moot either correct the error or explain why Lender believes the 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 pay any questioned amount while Lender is investigating, but you are still obligated to pay 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 Cinance charges rel~ted to any questioned 'amount. If Lender did not make a mistake, YOll 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 lhat it is due. If you fail to pay the amount that Lender thinks you owe, Lender may report you as delinq,uent. However, if Lender's explanation does not satisfy you and you write to Lender within ten days telling Lender that you still reCuse 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 collect the first $50 of the questioned amount, even if your bill was correct Alternative Dispute Resolution and Other Riders: The terms of the Arbitration Agreement ano any other Riders SIgned as part of ttllS loan transactlOn are IOcorporated IOto this Agreement by reference. Applicable Law: The terms and conditions of this Agreement will be governed by tne provisions of the Pennsylvania Consumer VIscount Company Act, Chapter 7, Sections 6201 througl\ 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 customerls) 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 )~~j-= (SEAL) ~~ (SEAL) Date: /O~IO- Dc Date: \() - \0- Od- .~ (SEAL) Witness: .(SEAL) . . , 03-01-00 RL F NftE PA056364 1111111111II11II111I111111111111.11111111.11 "L93B161S1N96RLA9000PA0563640""LEONE " ORIGI"'" . . '. . VERIFICATION Dawn Richt, Recover Specialist for Beneficial C~umer Discount COIDuanv Deposes and says subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities, that the facts set forth in the forgoing Complaint are true and correct to the best of her knowledge, information and belief. \\(~ V Dawn Richt N Q ~ ~ vt ~ U1 ........ ':-.:t ~ f;; ~ () 8 J:::. ~ ~ c ....' .' C"~ 0 ~ , c:::> -n ""'~ '- -< b L_~: :c,., j11p: ~ ('" -;::1r11 -c '-? 0 ..,...1 :'~) ~~\C} -r-' ~;]~~~ -..-. 0) ;':)rT1 ;:,:4 ;r:- !O '-" .< THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 05-3159 CIVIL TERM Plaintiff, vs. TYPE OF PLEADING: Praecipe for Default Judgment MICHAEL J. LEONE and KELLEY J. LEONE, TYPE OF CASE: Defendants. Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: Defendants' Address: 1110 FLORIBUNDA DRIVE MECHANICSBURG, P A 17055 CATHY ANN CHROMULAK, ESQUIRE PA ID NO. 42067 MELISSA A. SHENKEL, ESQUIRE PA ID NO. 91445 MAUREEN A. DOWD, ESQUIRE PAID NO. 90549 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, Pennsylvania 15317 Dated: JULY 26, 2005 (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 defendants, MICHAEL J. LEONE and KELLEY J. LEONE, for failure to file an Answer as follows: Amount Claimed in Complaint: $13,778.05 Interest from 5/11/05 through 7/26/05: 568.91 Costs of Collection through 7/26/05: 515.16 TOTAL $14,862.12 With interest accruing on the total balance of$14,862.12 at the rate of6% per annum, together with additional costs of suit. ByA ~ CAtHY ANN CHROMULAK, ESQUIRE MELISSA A SHENKEL, ESQUIRE MAUREEN A DOWD, 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 WASHINGTON 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 fplaintiffwho, being duly sworn according to law, deposes and says that 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 defendants on JULY 13, 2005 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attached copy. K~ CATHY ANN CHROMULAK, ESQUIRE MELISSA ASHENKEL, ESQUIRE MAUREEN A DOWD, ESQUIRE Sworn to and subscri ed before me This c:~ day 0 'w P~~ONWEAL.If:l OF PENNSYLVANIA THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. i'~'l\;::.:';'" Se-r1l Miche\lf'; L ,/lit);.(J\i;l.'\l.:'i*,' r'dblic COO' or. ''1'. \i'.'..,~h.nq;"" ;:}unty MyO')l'1:W(,:s,,:~,~\\ ~:mlj"& ,:uJy' 7. 2008 Meml1.r, P.ntlaYI;;;;i~'-A"~SQciatlon Of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. 05-3159 MICHAEL J. LEONE and KELLEY J. LEONE Defendant(s) TO: MICHAEL J. LEONE 1110 FLORIBUNDA DRIVE MECHANICS BURG, PA 17055 DATE OF NOTICE: JULY 13, 2005 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 IMPORT ANT 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, PA 17013 717-249-3166 or 800-990-9108 By: ~ - S\A- CATHY ANN CHROMULAK, 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. 05-3159 MICHAEL J. LEONE and KELLEY 1. LEONE Defendant( s) TO: KELLEY J. LEONE 1110 FLORIBUNDA DRIVE MECHANICSBURG, P A 17055 DATE OF NOTICE: JULY 13, 2005 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 MAY BE 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, PA 17013 717-249-3166 or 800-990-9108 By: M 5tA CATHY ANN CH~ULAK, 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 INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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' +- ,.... ~ C> ~ ~~ ~ j~:i;~ ~ r =e r ~ Cl ...., ,~-:',::> :;;, , r::: 'c-~ r'~) _1 C.J -n :-l _L- ('\~\:: :";,\-? )\() -- j'..) en ...0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 05-3159 CIVIL TERM Plaintiff, vs. MICHAEL J. LEONE and KELLEY J. LEONE, Defendants. NOTICE OF ORDER. DECREE OR JUDGMENT TO: MICHAEL J. LEONE 1110 FLORIBUNDA DRIVE MECHANICSBURG, P A 17055 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on , ) {-, .t \I .;(.7 .J on._, . l I ( ) A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $14,862.12 plus interest at the rate of 6% per annum and additional costs of suit. -------- ~()/hf Deputy ~ Q .711>> /i/l~ / 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, CIVIL DIVISION No. 05-3159 CIVIL TERM Plaintiff, vs. MICHAEL J. LEONE and KELLEY J. LEONE, Defendants. NOTICE OF ORDER. DECREE OR JUDGMENT TO: KELLEY J. LEONE 1110 FLORlBUNDA DRIVE MECHANICSBURG, P A 17055 (X) Defendant You are hereby notified that r ~der, Decree or Judgment was entered in the above captioned proceeding on "' A "f J- 7 ) (y,- )" . , ( ) A copy ofthe Order or Decree is enclosed, or (X) The judgment is as follows: $14,862.12 plus interest at the rate of 6% per annum and additional costs of suit. . ~ LlA 0/1.. 0 _~ . ~r/? /?J T L""-- Deputy 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, CIVIL DIVISION Plaintiff, No. 05-3159 CIVIL TERM vs. TYPE OF PLEADING: MICHAEL J. LEONE and KELLEY J. LEONE, Praecipe to Satisfy Judgment Defendants. TYPE OF CASE: Civil Action FILED ON BEHALF OF: Plaintiffs Addres~: 2700 Sanders Road Prospect Heights, IL 60070 BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ill NO. 42067 MICHAEL V. WORGUL, ESQ. PA ill NO. 93391 MAUREEN A. DOWD, ESQ. PA ill NO. 90549 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 05-3159 CNIL TERM Plaintiff, vs. MICHAEL J. LEONE and KELLEY J. LEONE, Defendants. PRAECIPE TO SATISFY JUDGMENT , TO PROTHONOTARY: Please satisfy the judgment against MICHAEL J. LEONE and KELLEY J. LEONE, at No. 05-3159 CNIL TERM, and mark the docket accordingly. Respectfully submitted, ::~oz; ~S~~TES' LLe CATHY ANN CH OMULAK, ESQ. PA ill NO. 42067 MICHAEL V. WORGUL, ESQUIRE PA ill NO. 93391 MAUREEN A. DOwn, ESQUIRE PA ill NO. 90549 Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscribed Before7fle this </ day ~ uti . ,2005. ll('~-k~J Notarial Seal ~ Michelle L. Wolot,. Not., Cecil Twp. , \i\!ashingt<- '~.~c. My Commission ~~pfr~~,_. _ ,,",,-'i~.J Member, Pennsvlvanj':~'\;;:"()eiati0n 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. W orgul, Esquire, counsel for BENEFICIAL 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 3rd day of October, 2005. MICHAEL J. LEONE KELLEY J. LEONE 1110 FLORIBUNDA DRVIE MECHANICSBURG, P A 17055 Jv~ ~Jc Michael V. W gul, Esq. 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