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Home My WebLink About05-3203 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY , Plaintiff, CIVIL DIVISION No. DS" - ~D3 Cil.),t ~Yrl vs. TYPE OF PLEADING: EDWARD P. THOMAS , Complaint Defendant. TYPE OF CASE: Civil Action Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY Defendant's Address: 711 SINCLAIR ROAD MECHANICSBURG, PAl 7055 COUNSEL OF RECORD: CATHY ANN CHROMULAJ(. ESQ. PA ID NO. 42067 MELISSA A. SHENKEL, ESQ. PA ID 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, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. EDWARDP. THOMAS 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 BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. OS' - J~c8 C!:1c...>;,.l:T ~ Plaintiff, vs. EDWARD P. THOMAS, 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. EDWARD P. THOMAS is an adult individual residing at 711 SINCLAIR ROAD, MECHANICSBURG, P A 17055. 3. On or about DECEMBER 18, 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 of the aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about DECEMBER 3], 2004. 6. Pursuant to the terms of the Loan Agreement, P]aintiffhas the right to require payment of the entire amount owed upon default. The total amount due, and owing by the Defendant is in the sum ofTHIRTEEN THOUSAND, TWO HUNDRED FIFTY EIGHT 27/]00 ($13,258.27) DOLLARS as of MAY ]6,2005. 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 THIRTEEN THOUSAND, TWO HUNDRED FIFTY EIGHT 27/100 ($13,258.27) DOLLARS, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC By:Ak .....CATHy ANN CHROMULAK, ESQ. PA ID NO. 42067 MELISSA A. SHENKEL, ESQ. PA ID NO. 91445 Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg,PA ]5317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. LOAN REPAYMENT AND SECURITY AGREEMENT (Page I of 3) LENDER (called "We", "Us". 'Our") BENEFICIAL CONSUMER DISCOUNT COMPANY 4910 CARLISLE PIKE SUI TE 104 MECHANICSBURG PA 11050 BORROWERS (called "Vou", "Vour") THOMAS. EDWARD P 5St 184382118 111 SINCLAIR RO MECHANICSeURG PA 11055 LOAN NO: 111114-553289 DAn Of lOAN f1aST ''''MEMT DUf DATf 12/18/2002 01/18/2003 TOTAl Df PAYMENTS AMOUNT f1H&J1tEO $ 15.256.20 TOTAL flHAIttE CHAR'E 1 .182.25 1 .182.25 LIfE INS PREMIUM DISABILITY '''' PREMIUM NONE $ REQUIRBD INSURANCE. You mus' obtain. insurance for term of loan coveri.as locuri.ty for this 108.0. as indicated below, !laming us as- Loss Payee: Title: insura.ace on real estate security. Fire end extended cover.ge iDsura.o.co on real estate IDCurity. Physical damage UuUtlt.ftCe en 1'&hicle lisled undor "Soeuri\y" above if "V. appear. under "lnsurod". Physical damage ulIuraoce Oil other propt:rty list<<! under ~SocuritJ" above if .V. appear. under "Insuroo". You 1087 obtai.l1 all)' required ic.suratloo from atlyone ,OU choose. (See .S~urit'" paragnph above for description of security to be inlured.) 63-01-00 NRE DI IONAL CONTRACT T RMS. IlIml~1111 .T850E5039P93CE~8000PA81 J EXHIBIT 1I011181UIII PAB15011 "A" DRIGIIW. LOAN REPAYMENT AND SECURITY AGREEMENT (Page 2 of 3) PAYMENT. In return for this loan, you will pay US the Total of Payments (the sum of Finance Charges plus Amount Financed), in monthly payments stated on page one. The Finance Charge is the total of Interest plus Service Charge. You may pay more at any time. You will pay us at our business address ... stated on page one or other address given you. If more than one Borrower is named on page one, we may enforce this Agreement against all. or any, Borrowers, but not in a combined amount greater than the amount owed. DA IE ON WHICH FINANCE CHARGE BEGINS. Finance Charges begin on the date of disbursement. If this loan is made by mail, the date on which the Finance Charge begins is postponed by the number of days from the date of this Agreement to the date of disbursement. Payment due dates and effective date of any optional insurance purchased are also postponed. PAY-QUTS. You agree to pay-outs of Amount Financed as shown on Truth-In-Lending disclosure form. If pay-outs change because loan closing is delayed, (a) you shall pay additional amounts due at closing, or (b) your cash or check will be reduced to cover additional pay-outs. PREPAYMENT. If you fully pay before final payment due date, the amount you owe will be reduced by unearned Finance Charge (but not Service Charge) determined by the 'Rule of 78tbs'. MATURITY. After tbe final payment due date stated on page one you will pay interestst the rate of 18% per year. SECURITY. You agree to give US a security interest in the property identified on page one, which will secure all indebtedness, including future advances under this Agreement. LATE CHARGE. If you don't pay any payment in 10 days after it's due, you will also pay I 112% per month on the amount overdue (subject to a $1.00 minimum charge). BAD CHECK CHARGE. We will charge you a fee of $20 if any payment check is returned because of insufficient funds or is otherwise dishonored. You agree that we may deduct this charge from a monthly payment. FAILURE TO PAY. If you don't pay any payment on time or fail to keep any required insurance in force, (a) all your payments may become due at once and without notifying you before bringing suit. we may sue for the total amount you owe less any unearned Finance Charges you would receive if you fully prepaid, and (b) you will also pay our reasonable attorney fees, if the anomey is not our salaried employee, for legal proceedings to collect this loan or realize on security. 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 inaurance 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 the sharing of such information (except for the sharing of information ahout transactions or experienees between us and youl by sending a written request which contains your full name, Social Security Number and Address to us at P.O. Bor 1547, Chesapeake, VA 23320. If you fail to fulfill the terma of your creclit 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 locste you. You agree that our supervisory personnel may listen to telephone calls between you sod our representatives in order to evaluate the quality of our service to you. INSURANCE. Optional credit insurance and any required insurance disclosures are attached to this Agreement and are incorporated herein by reference. ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDERS. The terms of the Arbitration Agreement and any other Riders signed as part of this loan transaction are incorporated into this Agreement by reference. APPLICABLE LAW. The Pennsylvania Consumer Discount Company Act (CDCA), Title 7, Purdon's Pennsylvania Statutes, governs this loan. NOTICE: THE FOLLOWING PAGE CONTAINS ADDITIONAL CONTRACT TERMS. 03-01-00 NftE PA875012 IIBWIIUlml~lllInllllllllllllllllmnl.llm 'T850E5039PS3CEASOOOPAB150120"lHOUAS . ORIGINAL 03-01-00 NRE LOAN REPAYMENT AND SECURITY AGREEMENT (Page 3 of 3) YOU HAVE RECEIVED A COMPLETE COPY OF THIS AGREEMENT AND THE TRUTH-IN-LENDING DISCLOSURES. BORROWERS~ E~~ (SEAL) (SEAL) (SEAL) WITNESS: qf./rvJ~( 1m . :;:h~ PA875013 I.ElllmIIIIUI.III~II.lnmlllllllllll -T850E5039P93CEA9000PA87SQ130WMTHOMAS . ORIGINAL VERIFICA nON Dawn Richt, Recover Specialist for ( Beneficial Consumer ~iscount Company 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. vl ./-_.......-- Dawn Richt D R 1l tt ~ ()'- ~ -- 6"- ~ Vi w ~ U( ~ ~ ~ ~ o (" ~, ~;~; 0 (...11 '1 8 c-;j H,::!:' r- rT1 o (L : ;f~:-~ ;_-:-1 :n '-< 1".) N C') _.1 SHERIFF'S RETURN - REGULAR CASE NO: 2005-03203 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS THOMAS EDWARD P BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon THOMAS EDWARD P the DEFENDANT , at 1715:00 HOURS, on the 28th day of June , 2005 at 711 SINCLAIR ROAD MECHANICSBURG, PA 17055 by handing to EDWARD P. THOMAS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.66 .00 10.00 .00 34.66 -'i.~--.", I' /,': ,.,.. _." ,'. <,,~~_~<.;~;:,.~ .r'- /.~3;~,,,,;,,,,,;,,,,,,,~-',,t_,, --.'. R. Thomas Kline Sworn and Subscribed to before 06/29/2005 CHROMULAK & ASSOCIATES By: ';L"" U j I tt~put;-:heriff me this s'~ day of 0..1)" 2ro:/ A.D. ( 1.,1" a 7H,PtJ..:d,~~ ~I rothonotary I '-=Ii THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 05-3203 - CNIL TERM Plaintiff, vs. TYPE OF PLEADING: Praecipe for Default Judgment EDWARDP. THOMAS, 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: 711 SINCLAIR ROAD 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,PA 15317 Dated: AUGUST 1,2005 (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 defendant, EDWARD P. THOMAS, for failure to file an Answer as follows: Amount Claimed in Complaint: Less Payment Made: Amount Owed: Interest from 5/17/05 through 8/01105: Costs of Collection through 8/01105: TOTAL $13,258.27 - 255.00 $13,003.27 -0- 499.16 $13,502.43 With interest accruing on the total balance of $13,502.43 at the rate of 6% per armum, together with additional costs of suit BY~ ~ 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 COUNTY OF WASHINGTON ) ) ) 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 fp laintiffwho, 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 defendant on JULY 19, 2005 by certifi ate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attached copy. ATH CHROMULAK, ESQUIRE MELISSA A. SHENKEL, ESQUIRE MAUREEN A. DOWD, ESQUIRE Sworn to and subscribed before me This ,.,? 9 day of , 2005. . tJ~oW THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Nota IilNWEALTH OF PENNSYLVANIA NOtarial Seal Michelle L W%m. Notnry Public Cedi Twp., \JI18f;hir1qli "~I /";nunty My Commission EXOi"~ '::!'! 7, 2008 Member, PennSYIVania-A~-s;;~iatjon Of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. 05-3203 CIVIL TERM EDWARDP. THOMAS Defendant(s) TO: EDWARDP. THOMAS 711 SINCLAIR ROAD MECHANICSBURG, PA 17055 DATE OF NOTICE: mLY 19,2005 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 mDGMENT 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,PA 17013 (717) 249-3166 or (800) 990-9108 By: .A AS'^-- / CATHY ~ 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. (Jl d' 3 . w ~ ;" :;-6 ->. [i'L~ .~~ ,,3 ~ [ ito <;; " ~ ;r '" j ~ ~ JJ-< '0 2 .. ;?:"z [t~ l!<~ ,,~ 8 9- o~ ~= ____'l lc--... ,~ ~~l j F'j ~ ~ !l' " ~~. i -I ! I "W ... i i -~ I~P ~ 3 .. ~::'.,.~ ,._~] i w 0 cn~g.@i ; ~Hh~i - ~il2f'H ~H~~!!~ ~i~~~t~~ " ~(U~'~ 5. . 0 (II ,. i;lF~ ~~~3~ 0 3 k. iD-1ll -13 a @iHhg ~il~3@"!!b ~~~f~U r~~~8 gnh~ ~::.i'll'i i~~3~O 5';j'- w'f u@~~. ~,~ <l':,~" :;;9-,8 a~i ..p:3~" ~~pe~ k~il ~ ~n~gl ~ ~~.w~~ iiog;' I iSh!}, I .... I ~ '" ~ I\) ",I" '" I\) '" J .... I-- ~ ~ ~ o lD 0> '@ -g ~ ~ ~ '@ '@ m ~~Og;",':;;' t! t! N Rl '@ ~ ~ ....o....~;::!'" _'" ~ ~ t! :m m ~ ~ z~~_z_tJ;:::>>~~V>tJV> - N Rl ~~8.~ tJ~~~zg~~~~dl~~~!i?~Cl .....~:r' n~ono",....,t>i"'-;:;::z <"'''' ~ @ e W "" >. ~ > ~o "~ ~ ~ ", ~ 8 · ~ ",z",ii",::;:;;l' ",:>>g;gjiiln-tJ~"'''' r-o .....,"';1'< ~:>> ",5J ~u, 6~ ~o gJn ",i:s ~Ei '2'" i:'@!; .~~~~~~~,,~~~~~~~~~. " > _" O,,^",.. "~...<.' i:i [ ~ _".~~1^~'~U"~O"R: tD &- N n :>>",-" '" 6i ", ", F .. ~ :r ~ :I: 9~o ...., ~ ~ ...., 5 a Cl l' '" :>> 0-> 'r- . ~ -;,. ." ~ . '" ...., :?:: :>> fj :>> C ...., :; :" J' ;;' :>> :I: n ~ > Z r ,n" "~d~q~p~l o"=~".'."" I .....ca;. ",_?,,,,r-"'''' ~ ... '" :>> ~ ?' _ r :>> 'l :>> - ~ ;;' '" ;;' '" V> :>>:>> c - '" '" 0- o '" '" o V> V> :::; 0- S '" 00 v, '" 00 '" " 'iP 6 t ~ '~ It IJ 1/ I-- '-... " I I I I I I I I I I ;T . ("'J z,. == ~ " ~ .' l. n ..... 2 ~ Zi >- ~ o "':j > z ....20~ '" :t:t2Ro OJ c: 0 ","''''> r-O'<oo 0-'" -0 O~:>> 00 > ",,,,....,0 - OJ s: ("'J u, ..... '< ~ > - '" tJ '"' trI ,00 t"" t"" o 'lC o '" o 3; n o ,. ~ ~ . lit oo-LJ~ ~ o~~O' ~ot:fQ.!l. [ !~~ f~ !!. -:;- 00 o~ !! -S'~P:~ ~ ii:D!!:E" lD g g a:; ~~ i~ "T1 _.w:l 2 :; -~~-g' . . ~ ~ 00:Il n ~ ~ ~:eJ!l '" ",-~~".g CIl t6; 0 :::r :+;:0;;' s"~.@l =)> 'J ~ S.-O ....0 wa ... ;Dr iiT - 3::0 S!.:: = ~ l1k~ ffi' a ::J ~ .. if ~ Ii ~ g it ~ ~ 2: 2 0 ll- <" ,.~ :; - ll. g ~i ~ ~~~ 10" .. ~I;ox 0(11 ::s ~ 001 o 2 ~ !..!!!. ii' "I, . 3 ':::1 "I :'11 11::1 :11 {,r :~:' Ii:::," ;1: 1..11',,'" ;":11 ,J: :.1'; ,,,,\1;11 ,.~:" '''''' ~I", "Ii "I', II 'II ~. ~I ~~ jt I it, . " ." ~I' ' c : ' ~III i ~ ',: I II H C~0 ~ ~__ 'l 8 c '" \;), l" ~ Vv D:! ~ .... t, r- Il.r () ~ -~ r : p ~:'; Cj ~~; ..or, :'~_ ::-,J c--: .....) fil . t (,.,0 (_.,~ -- '-f,) THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 05-3203 - CNIL TERM Plaintiff, vs. EDWARD P. THOMAS, Defendant. NOTICE OF ORDER. DECREE OR JUDGMENT TO: EDWARD P. THOMAS 711 SINCLAIR ROAD MECHANICSBURG, PA 17055 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on {JUl:f.1 . ,.:2/':V)., " . I () A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $13.502.43 plus interest at the rate of 6% per armum and additional costs of suit. 1 ~ ~ 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 CUMBERLANI) COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. 05-3203-CNIL TERM vs. TYPE OF PLEADING: EDWARD P. THOMAS, Praecipe to Satisfy Judgment Defendant. TYPE OF CASE: Civil Action Plaintiffs Address: 2700 Sanders Road Prospect Heights, 1L 60070 FILEI) ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ill NO. 42067 MELISSA A. SHENKEL, ESQ. PA ID NO. 91445 MAUREEN A. DOwn, ESQ. PA ID NO. 90549 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, P A 15317 (724) 916-2400 [THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 05-3203-CNIL TERM Plaintiff, vs. EDWARD P. THOMAS, Defendant. PRAECIPE TO SATISFY JUDGMENT TO PROTHONOTARY: Please satisfy the judgment against EDWARD P. THOMAS, at No. 05-3203-CNIL TERM, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. BY:~~_ CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MELISSA A. SHENKEL, ESQUIRE PA ID NO. 91445 MAUREEN A. DOwn, ESQUIRE PA ill NO. 90549 Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscribed Before me this /14 day of f)"3 ' 2005. ~~~IMlde~o~~~ o ary U Ie Notarial Seal Michelle L. WoIota. Notmy Public Cedi Twp.. Washlngt"., ( :"unly My c:ommission Expires ,iuly 7,2008 Member, Pennsylvania Association Of Notaries G THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, Melissa A. Shenkel, Esquire, counsel for 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 16th day of August, 2005. EDWARD P. THOMAS 711 SINCLAIR ROAD MECHANICSBURG, PA 17055 /1 3tA-- Melissa A. Shenkel, Esq. ~ THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY ~~?~~~~~~ ~~_~~~~~!~L Q ~,' ";:, ""0 (f. '=~-., {J:~ ~~~:~ 3. r-> .g Cf' ~ c:: G"> ,,~ fV ~ q q, .-I ft;~ -0" '23 -.0.1.- q,U :J~- :;; (',~~) ::::,,-,)rn '::::-\ '5 ::<:. v> - -