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Home My WebLink About05-5568IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 05 = S S(o 8 et . 1 f e Plaintiff, VS. STEVEN NELSON, TYPE OF PLEADING: Complaint TYPE OF CASE: Defendant. Civil Action Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 99 ST. JOHNS ROAD CAMP HILL, PA 17011 FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 MICHAEL V. WORGUL, ESQ. PA ID NO. 93391 CHROMULAK & ASSOCIATES, LLC 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 BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. STEVEN NELSON No. 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 CIVIL DIVISION DISCOUNT COMPANY, No. U 5. 5.5 G 8 C,?;j Tt-- Plaintiff, vs. STEVEN NELSON, 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. STEVEN NELSON is an adult individual residing at 99 ST. JOHNS ROAD, CAMP HILL, PA 17011. 3. On or about NOVEMBER 28, 2003, Defendant entered into a written Loan Agreement with the Plaintiff, a copy of which is attached hereto as "Exhibit A" and incorporated herein. 4. Pursuant to the Loan Agreement with Defendant, Plaintiff advanced funds to the Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5. Defendant is in default under the terms and conditions of the aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about MARCH 16, 2005. 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 Defendant is in the sum of NINE THOUSAND, TWO HUNDRED SIXTY EIGHT 84/100 ($9,268.84) DOLLARS as of SEPTMEBER 12, 2005. 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 NINE THOUSAND, TWO HUNDRED SIXTY EIGHT 84/100 ($9,268.84) DOLLARS, with interest thereon at the rate of 24% from SEPTMEBER 12, 2005, plus court costs and attorney's fees. Respectfully submitted, Chromu?lak & Associates, LLC By:ttt? CATHY ANN VUROMULAK, ESQ. PA ID NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 MICHAEL V. WORGUL, ESQ. PA ID NO. 93391 Attorneys for Plaintiff 375 Southpointe Boulevard 0 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 1 of 4) LENDER (called "We", "Us", "Our" BENEFICIAL CONSUMER DISCOUNT COMPANY 4910 CARLISLE PIKE SUITE 104 MECHANICSBURG PA 17050 BORROWERS (called "You", "Your") LOAN NO: 711714-17-508218 NELSON, STEVEN SS# 204465805 99 ST JOHNS RD CAMP HILL PA 17011 ANNUAL aoRnaY 1 OF AVERAGE DAILY aLLAMG! PERCENrAGE AEAIOD,C RAl! RATE 01 AND OVER 2.000 % e 24.000 % 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 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 obtain insurance for term of ban covering security for ibis loan agreement as indicated by the word 'YES" below, naming us as Loss Payee: 11128/03 50.001. 50. Physical damage insurance on vehicle listed under "Security" above, if 'Y' appears under "Insured.' You may obtain any required insurance from anyone you choose. BILLING ERRORS. I?MIa® 03-01-DD F NRE .............. AND RIGHTS 1 11 wll 11111111111 FAU56301 ORIOIML 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 ersona it 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 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 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 o this Agreement, tnc u ig 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 before 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 immediately an 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 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, terms 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 USE This notice contains 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, 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 not preserve your rights. NOTICE SEETHE FOLLOWING PAGE FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. F3NRE 00 I®III?II?® ®®®WM?W4gR1?Waaaa?111Y??IlA?®®®??I??? PA056363 ORIGINAL VERIFICATION Dawn Richt, Recover Specialist for Beneficial Consumer Mscount 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. Dawn Richt CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PENNSYLVANIA 15317 TELEPHONE (724) 916-2400 Eric Zdenek Legal Assistant Direct Dial: (724) 916-2413 EZdenek@Chromulak.com DATE: OCTOBER 24, 2005 TO: SHERIFF, CUMBERLAND COUNTY FACSIMILE (724) 916-2411 RE: BENEFICIAL CONSUMER DISCOUNT COMPANY v. STEVEN NELSON NO: Dear Sir/Madam: Enclosed for service please find the following documents: ()?' Complaint- Civil Action and check in the amount of 5100.00 for advance costs. ( ) Other: Instructions to the Sheriff to serve Defendant(s) are also enclosed. (D) Please return the Sheriff's Affidavit of Service and the receipt in the self-addressed, stamped envelope provided. If you have any questions, please call me at (724) 916-2413. Very truly yours, E Ok p U w N SHERIFF'S RETURN - REGULAR CASE NO: 2005-05568 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS NELSON STEVEN SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NELSON STEVEN the DEFENDANT , at 2050:00 HOURS, on the 21st day of November , 2005 at 99 ST JOHNS ROAD HILL. PA 17011 STEVEN NELSON by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the cont2nts thereof. Sheriff's Costs Docketing 18.00 Service 26.88 Affidavit .00 Surcharge 10.00 .00 54.88 Sworn and Subscribed to before me this day of aZU?J A. D. Prot ary So Answers: R. Thomas Kline 11/22/2005 CHROMULAK & ASSOCIATES By: Deputy Sh riff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. STEVEN NELSON, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 99 ST. JOHNS ROAD CAMP HILL, PA 17011 Dated: JANUARY 4, 2006 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 05-5568 CIVIL TERM TYPE OF PLEADING: Praecipe for Default Judgment TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQUIRE PA ID NO. 42067 LORI M. DIRENZO, ESQUIRE PA ID NO. 201843 NANCY C. WILKINS, ESQUIRE PA ID NO. 94178 JESSA C. MARTIN, ESQUIRE PA ID NO. 201169 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4`h Floor Canonsburg, PA 15317 (724) 916-2400 TO: PROTHONOTARY Please enter judgment by default against the within-named defendant, STEVEN NELSON, for failure to file an Answer as follows: Amount Claimed in Complaint: $ 9,268.84 Interest from 9/13/05 through 1/04/06: 604.10 Costs of Collection through 1/04/06: =19.38 TOTAL $10,392.32 With interest accruing on the total balance of $10,392.32 at the rate of 6% per annum, together with additional costs of suit. r - BY 41 CATHY ANN C ROMULAK, ESQ IRE LORI M. DIRENZO, ESQUIRE NANCY C. WILKINS, ESQUIRE JESSA C. MARTIN, 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 u signed aut ori1141A a Notary Public in and for said County and State, personally appeared, y(p) 1V_ ESQUIRE, attorney for and authorized representative of plaint- ho, being duly swoording 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 DECEMBER 20, 2005 by certificate of mailing in accordance with Pa.R.C.P. 237. 1, as evidenced by the a a hed copy. t C TH ANN C(HROMULAK, ESQUIRE LORI M. DIRENZO, ESQUIRE NANCY C. WILKINS, ESQUIRE JESSA C. MARTIN, ESQUIRE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Sworn to and subscribeoefore me Tti:_ 9/j I- k i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, Vs. STEVEN NELSON Defendant(s) TO: STEVEN NELSON 99 ST. JOHNS ROAD CAMP HILL, PA 17011 DATE OF NOTICE: DECEMBER 20, 2005 CIVIL DIVISION No. 05-5568 CIVIL TERM 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 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. By: Vkh t La'/ T CATHY ANN HROMULAK, ESQ. LORI M. DiRENZO, ESQ. NANCY C. WILKINS, ESQ. JESSA C. MARTIN, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 41h Floor Canonsburg, PA 15317 W Ate, (Ti p• 1V'i ? Q ? (O z D 1 p <? _ 1 l g? y N v T ° 6? Z Q H m ? a°^°p Z n5'ox to mt Vi ? ?m `? oZ, r79 ?rp`O p' Ln ?o m OZ ? ?? 9` m Y? dyni o me ???'m ' <?:7 ? ? d n =? b Cri nq° w pm A' tom g Z .s m? mo ? mt o? r^ m° ?o W r ?? no ? ?° no N t^ ~06 b P z ?_.1 j? N "Ti rjas i G .Y y. O n m 8 m mO^'mg a ? g W Om L? ¢ m "f J b $ ¢ 9 iR p ? ?mm`° rat m@ ? 39 Z ?n?m t"I a ° 6 6 m p0$ g v~ mu Sg?,? 9 aig oroa a °sg o p oaf 0- ?W ?yy, 3 ? o ¢¢ 2?, l,„„,m? U?NgI] & A ?w S6 CI .-n t:77 K fr?8'Rg V, 0 g w L, r G n THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 05-5568 CIVIL TERM Plaintiff, vs. STEVEN NELSON, Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: STEVEN NELSON 99 ST. JOHNS ROAD CAMP HILL, PA 17011 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on L1 (] / a 06& () A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $10,392.32 plus interest at the rate of 6% per annum and additional costs of suit. 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, vs. STEVEN NELSON, and M&T BANK, CIVIL DIVISION No. 05-5568 CIVIL TERM TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 99 ST. JOHN'S ROAD CAMP HILL, PA 17011 Defendant, Garnishee. Garnishee's Address: 100 SOUTH SPRING GARDEN CARLISLE, PA 17013 Date: January 19, 2006 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 LORI M. DIRENZO, ESQ. PA ID NO. 201843 NANCY C. WILKINS, ESQ. PA ID NO. 94178 JESSA C. MARTIN, ESQ. PA ID NO. 201169 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 BENEFICIAL CONSUMER DISCOUNT COMPANY, VS. STEVEN NELSON, and M&T BANK, TO: The Prothonotary Plaintiff, Defendant, Garnishee. CIVIL DIVISION No. 05-5568 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION Please issue a Writ of Execution in the above matter, 1. directed to the Sheriff of CUMBERLAND County; 2. against STEVEN NELSON, defendant, and 3. against M&T BANK, garnishee, 4. and index this writ a. against STEVEN NELSON, defendant, and b. against M&T BANK, garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual and joint, personal and business. Amount of Judgment Additional Interest to Date (Costs to be added) Pursuant to Writ of Execution And Service of Writ THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. $10,392.32 $ 17.30 $10,409.62 CATHY ANN CHROMULAK, ESQ. LORI M. DIRENZO, ESQ. NANCY C. WILKINS, ESQ. JESSA C. MARTIN, ESQ. ?• ?G ? r4-' .? ,2 ? ? -2 n c ?t f s C7 ?n _., ba. w ?'l ?'1 _' ?_ 6- R? -? ? -? ? - O ? ?;' C? ? ? ? ? -? f`? - 1 ?. ?. ? - .? `. .. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5568 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From STEVEN NELSON, 99 ST. JOHN'S ROAD, CAMP HILL, PA 17011 (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 M&T BANK, 100 SOUTH SPRING GARDEN, CARLISLE, PA 17013 -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 $10,392.32 Interest TO DATE - $17.30 Atty's Comm % Arty Paid $136.88 Plaintiff Paid Date: JANUARY 23, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs $.50 DUE GARNISHEE Prothonotary V7 By: Deputy REQUESTING PARTY: Name JESSA C. MARTIN, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4To FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 201169 SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-05568 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS NELSON STEVEN And now DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:48 Hours, on the 27th day of January , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT NELSON STEVEN in the hands, possession, or control of the within named Garnishee M & T BANK 100 SOUTH SPRING CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to MARJORIE L. WEINGERT (EMPLOYEE) 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 answers: r- Apoaft""AL# R. Thomas Klin&l Sheriff of Cumberland County 01/30/2006 Sworn and subscribed to before me this y`= day of? ? A. D. Pro onotar By J %l Zil/y/? Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. STEVEN NELSON, 99 ST. JOHN'S ROAD CAMP HILL, PA 17011 and M&T BANK TO: M&T BANK Defendant, Garnishee. 100 SOUTH SPRING GARDEN CARLISLE, PA 17013 CIVIL DIVISION No. 05-5568 CIVIL TERM You are required to file Answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. .qn.Su ,' 5 1L9 INTERROGATORIES TO GARNISHEE FIRST: At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him/her on any negotiable or other written instrument, or did he/she claim that you owed him/her any money or that you were liable to him/her for any reason: RESPONSE: -Z1 ?rtiPeC?y,r.q 'Vipl W?? f fly/ Y f t ? ?-P SECOND: If your response to the previous interrogatory was anything other than an unqualified negative, set forth the amount of the claim, and identify the written instrument, if any, that forms the basis of the claim. RESPONSE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. I THIRD: At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the Defendant? The scope of this interrogatory encompasses, but is not restricted to, the contents of any bank account(s). RESPONSE: )6 ? FOURTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: FIFTH: At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the Defendant (or in which Defendant) held or claimed any interest. RESPONSE: N ?NP? SIXTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: SEVENTH: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which the Defendant had any interest? RESPONSE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EIGHTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: NINTH: At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefore? RESPONSE: ?? C 1 TENTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount, and state the date of the transfer and the name and address of the transferee(s). RESPONSE: ELEVENTH: At any time after you were served, did you pay, transfer or deliver any money or property of the Defendant or to any person or place pursuant to their direction or otherwise discharge any claim of the Defendant against you? RESPONSE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 'TWELFTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, in the case of monetary assets, state the amount, and state the date of transfer and the name and address of the transferee(s). RESPONSE: 1 C Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. DATE: j"I I l.? By: ?J I?,JGC/ Cathy Ann Chromulak, Esq. Lori M. DiRenzo, Esq. Nancy C. Wilkins, Esq. Jessa C. Martin, Esq. 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 BENEFICIAL CONSUMER DISCOUNT COMPANY, VS. STEVEN NELSON, and Plaintiff, Defendant, M&T BANK, Garnishee. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 05-5568 CIVIL TERM TYPE OF PLEADING: Praecipe For Judgment Against Garnishee TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 LORI M. DiRENZO, ESQ. PA ID NO. 201843 NANCY C. WILKINS, ESQ. PA ID NO. 94178 JESSA C. MARTIN, ESQ. PAID NO. 201169 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4m Floor Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, VS. STEVEN NELSON, and M&T BANK, TO: PROTHONOTARY Plaintiff, Defendant, Garnishee. CIVIL DIVISION No. 05-5568 CIVIL TERM Please enter judgment against Garnishee, M&T BANK, in the amount of $657.67 based upon the Garnishee's Answers to Interrogatories attached hereto as Exhibit A admitting possession of funds of Defendant in that amount, which is less than Plaintiff's judgment against the Defendant, interest and costs. Respectfully submitted, CHROMULAK & ASSOCIATES, LLC. ByJ Cathy Ann Chromulak, Esquire Lori M. DiRenzo, Esquire Nancy C. Wilkins, Esquire Jessa C. Martin, Esquire Attorneys for Plaintiff THIS IS AN ATTEMPT TO 375 Southpointe Boulevard COLLECT A DEBT AND ANY 4th Floor INFORMATION OBTAINED WILL Canonsburg, PA 15317 BE USED FOR THAT PURPOSE. M M&T Bank February 16, 2006 Chromulak & Assoc. 375 Southpointe Blvd. 4r" Fir. Canonsburg, PA 15317 Legal Document Processing Phone # 716.635-7712 Fax # 716-635-7725 Re: Writ of Garnishment on Garnishee received by Manufacturers and Traders Trust Company, Garnishee Beneficial Consumer Discount vs. Steven Nelson Pursuant to the above referenced Writ of Garnishment and Interrogatories on Garnishee, manufacturers and Traders Trust Company has searched its records and has identified the following account(s) with balances due its customer(s) as of June 6 2005. Acct No. Balance Acct No. Balance 2687187 $657.67 If the Writ of Garnishment and Interrogatories also sought to restrain access to safe deposit boxes, then any safe deposit boxes identified at any of our branches are listed below. Branch Number- Safe Deposit Box Number None If any of the above accounts or safe deposit boxes are designated by a "P" that means they are accounts or safe deposit boxes in which persons other than those identified in the Writ of Garnishment and Interrogatories may also have an interest. With respect to all safe deposit boxes, an order directing the drilling of the box must first be obtained and Manufacturers and Traders Trust Company must be reimbursed for the cost of drilling and replacing the lock on the box. P&R.C.P. No. 3110, 42 Pa.C.S.A. Responses to Interrogatories that you propounded, if any, are enclosed. Sincerely, Kelly C. Inclima Legal Document Analyst (716) 635-7712 Enclosure: Responses to Interrogatories A Manufacturers and Traders Trust Company ox 4, Buffalo, New York 14240 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL DIVISION No. 05-5568 CIVIL TERM VS. STEVEN NELSON, 99 ST. JOHN'S ROAD CAMP HILL, PA 17011 Defendant, and M&T BANK Garnishee. TO: M&T BANK 100 SOUTH SPRING GARDEN CARLISLE, PA 17013 You are required to file Answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. INTERROGATORIES TO GARNISHEE FIRST: At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him/her on any negotiable or other written instrument, or did he/she claim that you owed him/her any money or that you were liable to him/her for any reason: RESPONSE: 4Gzf?.(-o --7 SA iL' ? -i') . NW-\5??1 SECOND: If your response to the previous interrogatory was anything other than an unqualified negative, set forth the amount of the claim, and identify the written instrument, if any, that forms the basis of the claim. RESPONSE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIRD: At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the Defendant? The scope of this interrogatory encompasses, but is not restricted to, the contents of any bank account(s). RESPONSE: U \? FOURTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: FIFTH: At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the Defendant (or in which Defendant) held or claimed any interest. RESPONSE: 0` SIXTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: SEVENTH: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which the Defendant had any interest? RESPONSE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. V`-) v EIGHTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: NINTH: At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefore? RESPONSE: ?)l C TENTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount, and state the date of the transfer and the name and address of the transferee(s). RESPONSE: ELEVENTH: At any time after you were served, did you pay, transfer or deliver any money or property of the Defendant or to any person or place pursuant to their direction or otherwise discharge any claim of the Defendant against you? RESPONSE: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CERTIFICATE OF SERVICE I, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe for Judgment Against Garnishee was served upon the following by First Class Mail, postage prepaid on this 1 st day of March, 2006. M&T BANK KELLY C. INCLIMA P.O. BOX 844 BUFFALO, NY 14240 STEVEN NELSON 99 ST. JOHN'S ROAD CAMP HILL, PA 17011 ?,yf Cathy Ann Chromulak, Esq. Lori M. DiRenzo, Esq. Nancy C. Wilkins, Esq. Jessa C. Martin, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ? ?? ?-- ? w ? ? ? r_ C -?A- d ?-- ,, ?' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. STEVEN NELSON, and M&T BANK, Defendant, Garnishee. CIVIL DIVISION No. 05-5568 CIVIL TERM TYPE OF PLEADING: Praecipe to Satisfy Judgment Against Garnishee ONLY TYPE OF CASE: Civil Action FILED ON BEHALF OF: Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 NANCY C. WILKINS, ESQ. PAID NO. 94178 JESSA C. MARTIN, ESQ. PA ID NO. 201169 AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 Date: April 19, 2006 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4m 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, VS. STEVEN NELSON, and M&T BANK, Defendant, Garnishee. CIVIL DIVISION No. 05-5568 CIVIL TERM PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please satisfy the judgment in this action against the above garnishee, M&T BANK and mark the docket accordingly. Sworn to and subs bed Before e this _day of ?__ 2006. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By:1? CATHY AN,?I CHROMULAK, ESQUIRE NANCY C. WILKINS, ESQUIRE JESSA C. MARTIN, ESQUIRE AMY L. SABOLCHICK, ESQUIRE Attorneys for Plaintiff 375 Southpointe Boulevard 4`h Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO v q COLLECT A DEBT AND ANY '.1 1C Noranai3eai INFORMATION OBTAINED WILL MidldeL i,%' 11'a, Notary PL"IiC BE USED FOR THAT PURPOSE. CeolTwp. t&'a?N'-43 county My Commission , Aorep Jdy 7.20D8 1 CERTIFICATE OF SERVICE I, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy the Judgment Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 19th day of April, 2006. M&T BANK C/O TALIA P.O. BOX 844 BUFFALO, NY 14240 STEVEN NELSON 99 ST. JOHN'S ROAD CAMP HILL, PA 17011 Cathy AmVChromulak, Esq Nancy C. Wilkins, Esq. Jessa C. Martin, Esq. Amy L. Sabolchick, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. C? ??- ? ?? - C _ C -..._ ?' ? ..? `,,, C ? ? -E-- -?-- _-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, VS. STEVEN NELSON, and M&T BANK, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 99 ST. JOHN'S ROAD CAMP HILL, PA 17011 Plaintiff, Defendant, Garnishee. Garnishee's Address: 100 SOUTH SPRING GARDEN CARLISLE, PA 17013 Date: May 17, 2006 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 05-5568 CIVIL TERM TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 NANCY C. WILKINS, ESQ. PA ID NO. 94178 JESSA C. MARTIN, ESQ. PA ID NO. 201169. AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, VS. STEVEN NELSON, and M&T BANK, TO: The Prothonotary Plaintiff, Defendant, Garnishee. CIVIL DIVISION No. 05-5568 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION Please issue a Writ of Execution in the above matter, 1. directed to the Sheriff of CUMBERLAND County; 2. against STEVEN NELSON, defendant, and 3. against M&T BANK, garnishee, 4. and index this writ a. against STEVEN NELSON, defendant, and b. against M&T BANK, garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendant in any accounts, individual and joint, personal and business. 5. Amount of Judgment Additional Interest to Date Less payments made (Costs to be added) Pursuant to Writ of Execution And Service of Writ THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. $10,392.32 - 47qy • loS $ 345.37 $ 647.67 $10,090.02 CA HY ANN CHROMULAK, ESQ. NANCY C. WILKINS, ESQ. JESSA C. MARTIN, ESQ. AMY L. SABOLCHICK, ESQ. G J v 1 1 ^? i co WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5568 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From STEVEN NELSON, 99 ST. JOHN'S ROAD, CAMP HILL, PA 17011 (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 M&T BANK, 100 SOUTH SPRING GARDEN, CARLISLE, PA 17013 - ALL MONIES DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS. GARNISHEE(S) as follows: and to notify the gamishee(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 $9,744.65 Interest TO DATE Atty's Comm % Arty Paid $158.38 Plaintiff Paid Date: June 23, 2006 (Seal) L.L Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary By: Deputy REQUESTING PARTY: Name NANCY C. WILKINS, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 94178 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. and STEVEN NELSON, 99 ST. JOHN'S ROAD CAMP HILL, PA 17011 M&T BANK Defendant, Garnishee. TO: M&T BANK 100 SOUTH SPRING GARDEN CARLISLE, PA 17013 CIVIL DIVISION No. 05-5568 CIVIL TERM You are required to file Answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. 4-0 INTERROGATORIES TO GARNISHEE nSLJ e r-5 RESPONSE: ?O FIRST: At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him/her on any negotiable or ether written instrument, or did he/she claim that you owed him/her any money or that you werep liable to him/her for y reason. RESPONSE: SECOND: If your response to the previous interrogatory was anything ote unqualified negative, set forth the amount of the claim, and identify the written a if any, that forms the basis of the claim. 'pC THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. y ? THIRD: At the time you were served or at any subsequent time, was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the Defendant? The scope of this interrogatory encompasses, but ' not restricted to, the contents of any bank account(s). RESPONSE: FOURTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: ?101- FIFTH: At the time you were served or at any subsequent time, did you hold legal title to any property of any nature owned solely or in part by the Defendant (or in which Defendant) held or claimed any interest. RESPONSE: 0(0 SIXTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: 011- SEVENTH: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which the Defendant had any interest? RESPONSE: ? \ THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. i ._ go EIGHTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount. RESPONSE: NINTH: At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefore? RESPONSE: r1 TENTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, and in the case of monetary assets, state the amount, and state the date of the transfer and the name and address of the transferee(s). RESPONSE: o-- ELEVENTH: At any time after you were served, did you pay, transfer or deliver any money or property of the Defendant or to any person or place pursuant to their direction or otherwise discharge any claim of the Defendant against you? RESPONSE: 0 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ,. TWELFTH: If your response to the previous interrogatory was anything other than an unqualified negative, identify the property, in the case of monetary assets, state the amount, and state the date of transfer and the name and address of the transferee(s). RESPONSE: lsubmitted, CHROMULAK & ASSOCIATES, L.L.C. DATE: I AIL 0 6 2006 TALIA s_ A7? M & T BANK LEGAL DOCUMENT PROCESSING P.O. BOX 844 BUFFALO, NY 14240 Y6 B Y? Cathy Ann Chromulak, Esq. Nancy C. Wilkins, Esq. Jessa C. Martin, Esq. Amy L. Sabolchick, Esq. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. h W 9C?1 95 ?$ ? v h 1 :01 V `l Z Nl q,OZ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, Plaintiff, No. 05-5568 CIVIL TERM VS. TYPE OF PLEADING: STEVEN NELSON, Praecipe to Discontinue Against Garnishee ONLY Defendant, and TYPE OF CASE: M&T BANK, Civil Action Garnishee. FILED ON BEHALF OF: BENEFICIAL CONSUMER Plaintiff's Address: DISCOUNT COMPANY 2700 Sanders Road Prospect Heights, IL 60070 COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 LORI M. DIRENZO, ESQ. PA ID NO. 201843 AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 ANNA M. BONARRIGO, ESQ. PA ID NO. 202070 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4`s 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 CIVIL DIVISION DISCOUNT COMPANY, Plaintiff, No. 05-5568 CIVIL TERM VS. STEVEN NELSON, and M&T BANK, Defendant, Garnishee. PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please discontinue this action against the above garnishee, M&T BANK and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C By: V lV,-V I V / l?l/ CATHY ANN CHROMULAK, ESQ LORI M. DIRENZO, ESQUIRE AMY L. SABOLCHICK, ESQUIRE ANNA M. BONARRIGO, ESQUIRE Attorneys for Plaintiff 375 Southpointe Boulevard 4`h Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Sworn to and subscribed Bef xr me this _/R_day of "? . 2006. CERTIFICATE OF SERVICE I, counsel for BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Discontinue Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 12th day of JULY, 2006. TALIA S. PALMER P.O. BOX 844 BUFFALO, NA 14240 STEVEN NELSON 99 ST. JOHN'S ROAD CAMP HILL, PA 17011 Cathy Ann Chromulak, Esq. Lori M. DiRenzo, Esq. Amy L. Sabolchick, Esq. Ana M. Bonarrigo, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. (J ? Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff s Costs: Advance Costs: 150.00 Sheriffs Costs: 84.56 Docketing 18.00 $ 65.44 Poundage 1.66 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 06/05/06 Mileage 4.40 Surcharge 30.00 Levy 20.00 Certified Mail Post Pone Sale Garnishee 9.00 Postage TOTAL $ 84.56 So Answers; R VTIhh ma Kline, Sh ?? B u is rewb er hS :I d 9Z NYf 9001 Vd ',kiN(100 0HV-1830wn3 AA183HS 3HI A 391. 30 C2?; f -)' Y ? 5'c t:r... ?y3/'7 J4,,, /79/03 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5568 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From STEVEN NELSON, 99 ST. JOHN'S ROAD, CAMP HILL, PA 17011 (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 M&T BANK, 100 SOUTH SPRING GARDEN, CARLISLE, PA 17013 - 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 $10,392.32 Interest TO DATE - $17.30 L.L. $.50 Atty's Comm % Atty Paid $136.88 Plaintiff Paid Date: JANUARY 23, 2006 (Seal) REQUESTING PARTY: Name JESSA C. MARTIN, ESQUIRE Due Prothy $1.00 Other Costs $.50 DUE GARNISHEE Prot onotary" Deputy Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 201169 SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-05568 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS NELSON STEVEN And now KENNETH GOSSERT Sheriff or Cumberland County of Pennsylvania, who being duly to law, at 0014:41 Hours, on the 30th day of June as herein commanded all goods, chattels, rights, moneys of the within named DEFENDANT , NELSON STEVEN Deputy Sheriff of sworn according 2006, attached debts, credits, and , in the hands, possession, or control of the within named Garnishee M & T BANK 1 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to LINDSEY RICHARDS (ADULT IN CHARGE) 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 apojwae!?? Docketing .00 ?Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .001/ Sworn and Subscribed to before me this day of 07/05/2006 By A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION: DISCOUNT COMPANY, No. 05-5568 CIVIL TERM PLAINTIFF, TYPE OF PLEADING: VS. STEVEN NELSON, MOTION TO COMPEL ANSWERS TO INTERROGATORIES IN AID OF EXECUTION DEFENDANT. FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK PA ID No. 42067 AMY L. SABOLCHICK PA ID No. 94653 ANNA M. BONARRIGO PA ID No. 202070 CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4T`` FLOOR CANONSBURG, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY PLAINTIFF, vs. STEVEN NELSON, DEFENDANT. CIVIL DIVISION: No. 05-5568 CIVIL 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., and moves this Court for an Order, pursuant to Pa.R.Civ.P. 4019, to compel the Defendant, STEVEN NELSON, to respond to interrogatories and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant was entered on January 9, 2006 in the sum of $10,392.32. 2. Plaintiff served interrogatories upon STEVEN NELSON, via first class mail on April 10, 2006. 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 11, 2006. A true and correct copy of the demand letter is attached hereto as Exhibit "B" and incorporated 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 STEVEN NELSON to answer the interrogatories. WHEREFORE, Plaintiff respectfully requests the Court to approve the proposed Order annexed hereto. /Al CATHY CHROMULAK PA ID No. 42067 AMY L. ABOLCHICK PA ID No. 94653 ANNA M. BONARRIGO PA ID No. 202070 CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PENNSYLVANIA 15317 (724) 916-2400 (724) 916-2411 (FACSIMILE) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, C'nM, DIVICInN: PLAINTIFF, No. 05-5568 CIVIL, TERM vs. STEVEN NELSON, INTERROGATORIES IN AID OF EXECUTION DIRECTED TO DEFENDANT. DEFENDANT STEvEN NELSON BENEFICIAL CONSUMER DISCOUNT COMPANY CATHY ANN CHROMULAK PA ID No. 42067 NANCY C. WILKINS PA ID No. 94178 JESSA C. MARTIN PA ID No. 201169 AMY L. SABOLCHICK PA ID No. 94653 CHROMULAK & ASSOCIATES LLC 375 Southpointe Blvd. 4t' Floor Canonsburg, PA 15317 (724) 916-2400 April 10, 2006 You are Hereby Notified to Plead to the Enclosed Interrogatories Within 30 Days Fro°? Servic Hereof. 1? 0-." 1 I!( i,' Attorney for Plaintiff EXHIBIT g D a 3 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, PLAINTIFF, No. 05-5568 CIVIL TERM vs. STEVEN NELSON, DEFENDANT. INTERROGATORIES IN AID OF EXECUTION DIRECTED TO DEFENDANT STEVEN NELSON TO: Steven Nelson 99 St. John's Road Camp Hill, PA 17011 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 thin (30) rlavc- in accordance with 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 your 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 your 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 in detail. ANSWER: 6. Are you married? ANSWER: 7. Do you own or have any interest in any land/real estate? 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 in answering 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: a. b. C. d. 10. What Individual Retirement Account (IRA) do you own? ANSWER: 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 12. Do you belong to a credit union or other work related savings plan? If yes, describe. ANSWER: 13. What stocks, shares, bonds, notes and shares in a mutual funds do you own or have an interest in? ANSWER: a. b. 14. Does any individual, partnership, or corporation owe you money? If yes, provide details of the debt. ANSWER: 15. Do you own life insurance? If yes, list the insurance company and policy number. ANSWER: 4 16. What televisions, stereos, VCRs, camcorders, cameras 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 firearms 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: 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 description 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 description of the property; the name and address of the person, firm, or other entity who has possession of the property; the circumstances and reason why the property is in possession of the third person; 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, model, title number, serial number and registration plate number. Also show the name or names in which each motor vehicle is registered, the 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, the 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. Include all utilities, rent/mortgage, credit cards, and other loans, and any other monthly payments made by you. ANSWER: 1 CATHY ANN CHIC MULAK PA ID 42067 NANCY C. WILKINs PA ID 94178 JESSA C. MARTIN PA ID 201169 AMY L. SABOLCHICK PA ID 94653 CHROMULAK & ASSOCIATES LLC 375 SOLM PONM BLVD e FLOOR CANONSBURG, PA 15317 (724) 916-2400 (724) 916-2411 APRIL 10, 2006 8 I, counsel for Beneficial Consumer Discount Company, hereby certify that a true and correct copy of the foregoing Interrogatories in Aid of Execution were served via U.S. First Class Mail v?- onthe following, this ? day of , , 2006: Steven Nelson 99 St. John's Road Camp Hill, PA 17011 Cathy Ann Chromulak, Esquire Nancy C. Wilkins, Esquire Jessa C. Martin, Esquire Amy L. Sabolchick, Esquire CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PENNSYLVANIA 15317 TELEPHONE (724) 916-2400 FACSIMILE (724) 916-2411 Nancy C. Wilkins Attomey- At-Law nwilkins@chromulalcom May 11, 2006 Steven Nelson 99 St. John's Road Camp Hill, PA 17011 RE: Beneficial Consumer Discount Company vs. Steven Nelson No. 05-5568 CIVIL TERM; Cumberland County, Pennsylvania Dear Mr. Nelson: On April 10, 2006, 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. You should: a) Immediately respond to the Interrogatories; or b) Contact my office and set up acceptable payment arrangements. If my office does not hear from you by May 22, 2006, we may proceed with further legal action against you. Very truly ours, Nancy C. Wilkins NCW/mjc THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT a a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION: DISCOUNT COMPANY, PLAINTIFF, vs. STEVEN NELSON, DEFENDANT. No. 05-5568 CIVIL TERM TYPE OF PLEADING: MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL ANSWERS TO INTERROGATORIES IN AID OF EXECUTION FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK PA ID No. 42067 AMY L. SABOLCHICK PA ID No. 94653 ANNA M. BONARRIGO PA ID No. 202070 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 BENEFICIAL CONSUMER DISCOUNT COMPANY, PLAINTIFF, vs. STEVEN NELSON, DEFENDANT. CIVIL DIVISION: No. 05-5568 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 9, 2006 in the amount of $10,392.32. Plaintiff served interrogatories upon STEVEN NELSON, via first class mail on April 10, 2006. Pursuant to Pa.R.Civ.P. 4006 (a)(2), Defendants' 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 11, 2006. 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. 4019(a)(1)(i) compelling STEVEN NELSON to answer the interrogatories. ARGUMENT Rule 4019(a)(1)(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 April 10, 2006 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 enter the proposed Order attached to Plaintiff's Motion to Compel Answers to Interrogatories, and compel STEVEN NELSON to answer said interrogatories. 6 , CATHY A CHROMULAK PA ID No. 42067 AMY L. S BOLCHICK PA ID No. 94653 ANNA M. BONARRIGO PA ID No. 202070 CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4T' FLOOR CANONSBURG, PENNSYLVANIA 15317 (724) 916-2400 (724) 916-2411 (FACSIMILE) CERTIFICATE OF SERVICE I, 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 4 h day of October, 2006: STEVEN NELSON 99 St. John's Road Camp Hill, PA 17011 Cathy Chromulak, Esq. Amy L. abolchick, Esq. Anna M. Bonarrigo, Esq. r-? CD - •• 1 OCT 0 9 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, PLAINTIFF, vs. STEVEN NELSON, DEFENDANT. CIVIL DIVISION' No. 05-5568 CIVIL TERM ORDER AND NOW, this q day of Oc44,,- , 2006, upon consideration of Plaintiffs Motion to Compel Answers to Interrogatories In Aid of Execution, it is hereby ORDERED that the Motion is GRANTED. Defendant STEVEN NELSON must make full and complete answer to the interrogatories, without objection or motion for a protective order, within thirty (30) days of the date of this Order or appropriate sanctions will be imposed upon Defendant following application to the Court. J. 7611, 11\0 t_ fl, vr? `''?11'J a -Al. K, i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, Pl aintiff, No. 05-5568 CIVIL TERM VS. TYPE OF PLEADING: STEVEN NELSON, Praecipe to Satisfy Judgment D fendant. TYPE OF CASE: Civil Action Plaintiff's Address: FILED ON BEHALF OF: 2700 Sanders Road Prospect Heights, IL 60070 BENEFICIAL CONSUMER DISCOUNT COMPANY V III COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 CHRISTINE A. SAUNDERS, ESQ. PA ID NO. 203373 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 IIII II THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1 IN THE COURT OF COMMON BENEFICIAL CONSUMER DISCOUNT COMPANY, VS. STEVEN NELSON, TO TO PROTHONOTARY: Please satisfy the and mark the docket OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No. 05-5568 CIVIL TERM against STEVEN NELSON, at No. 05-5568 CIVIL TERM, Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. CATHY ANN CHRO LAK, ESQ. PA ID NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 CHRISTINE A. SAUNDERS, ESQ. PA ID NO. 203373 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscribed Before Nk is _ M day of , 2007. L Notary -•-.-. - vivJ rLvmiL ice. otana Seal leather L atfielb, Notary Put,,;.. %ecil Twp. Washington Count,. "`v C.ommiss n E)OrGs June 29, 2Q i is THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1 CATE O I, counsel for BENEFICIAL and correct copy of the fore by First Class Mail, postage DISCOUNT COMPANY, hereby certify that a true Praecipe to Satisfy Judgment was served upon the following aid on this 7th day of June, 2007. STEVEN NELSON 99 ST. JOHN'S ROAD CAMP HILL, PA 17011 Cathy Ann Chromul , Esq. Maureen A. Dowd, Esq. Christine A. Saunders, Esq. Beth Arnold Howell, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. `"'v- ? ° ? C? ? c_..- -n ' . s _> ?? y:V;?~ ? R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Advance Costs: 150.00 84.05 Docketing 18.00 $ 65.95 Poundage 1.65 Advertising Law Library Prothonotary 1.00 Refunded to Atty on 06/22/07 Mileage 4.40 Surcharge 30.00 Levy 20.00 Certified Mail Post Pone Sale Garnishee 9.00 Postage Qom TOTAL $ 84.05 So, Answers; R. Thomas Kline, Sheriff C' i , - By Claudia A. Brew aker LS :8 V h Z XVW 9002 S 1 :01 V 9Z NAr 9001 VJ- ;'JJ 1JUj lC:.;J 091 {'1}.s JJ18]NS INI a0 301JJ0 0 9k QN ?e j"vo CAL y'gIJZ i9yair WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5568 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From STEVEN NELSON, 99 ST. JOHN'S ROAD, CAMP HILL, PA 17011 (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 M&T BANK, 100 SOUTH SPRING GARDEN, CARLISLE, PA 17013 - ALL MONIES DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $9,744.65 L.L. Interest TO DATE Atty's Comm % Atty Paid $158.38 Plaintiff Paid Date: June 23, 2006 (Seal) Due Prothy $1.00 Other Costs URTIS OG NProthonotary By: Deputy REQUESTING PARTY: Name NANCY C. WILKINS, ESQUIRE Address: CHROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 94178