HomeMy WebLinkAbout06-0555IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
Plaintiff, CIVIL DIVISION
V5.
No.Ot. -5
DEBRA R. CAMPBELL
A/K/A DEBRA R. DAVIS
Defendant(s)
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT.
C?tu?, C(-T?
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
CIVIL DIVISION
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY, No. Ot, -S'$S (2Iu i t
Plaintiff,
VS.
TYPE OF PLEADING:
Complaint
DEBRA R. CAMPBELL
AJK{A DEBRA R. DAVIS,
Defendant.
Plaintiff s Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
427 NORTH PITT STREET
CARLISLE, PA 17013
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
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, LLC
375 Southpointe Boulevard
4`h Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION
DISCOUNT COMPANY, //
No. OCo
Plaintiff,
VS.
DEBRA R. CAMPBELL
AlK)A DEBRA R. DAVIS,
Defendant.
COMPLAINT
AND NOW COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY, by its Attorneys, Chromulak & Associates, LLC, with its Civil
Action Complaint, the following of which is a statement thereof:
1. HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY is a
Corporation, duly authorized to conduct business in the Commonwealth of Pennsylvania, with its
principal office situated at 2700 Sanders Road, Prospect Heights, IL 60070, hereinafter referred
to as "Plaintiff'.
2. DEBRA R. CAMPBELL A/K/A DEBRA R. DAVIS is an adult individual
residing at 427 NORTH PITT STREET, CARLISLE, PA 17013.
3. On or about JULY 24, 2004, 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.
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 SEPTEMBER 1, 2005.
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 Defendant is in the sum of NINE THOUSAND FIVE HUNDRED
THIRTY-SIX AND 85/100 ($9,536.85) DOLLARS as of DECEMBER 15, 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 FIVE
HUNDRED THIRTY-SIX AND 851100 ($9,536.85) DOLLARS, with interest thereon at the rate
of 23.75% from DECEMBER 15, 2005, plus court costs and attorney's fees.
Respectfully submitted,
Chromulak & Associates, LLC
By:
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
Attorneys for Plaintiff
375 Southpointe Boulevard
THIS IS AN ATTEMPT TO 4"' Floor
COLLECT A DEBT AND ANY Canonsburg, PA 15317
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
Personal Credit Line Account Agreement
(Page I of 3)
LENDER (called "We", "Us", "Our")
HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY
25 GATEWAY DRIVE
GATEWAY SOUARE7SUITE 107
MECHANICSBURG PA 17055
BORROWERS (called "You", "Your") LOAN NO. 713303-15-13o389
CAMPBELL, DEBRA R
SSR 200358853
427 N PITT ST
CARLISLE PA 17013
INITIAL ANNUAL
INITIAL MONTNIY PERCENTAGE
ON PORTION Of AVERAGE DAILY BALANCE PERIODIC RATE RATE: CREDIT LIMIT DATE Of LOAN MARGIN
.01 AND OVER 1.350 % 21.000 % 8500 07!24!04 17.00000%
MITI" AANUAL SUBSEQUENT ANNUAL FEES
EE
S 50.00 It 50.00
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.
)',,or Personal Credit Line 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.
&EQUIRED INSURANCE. You may obtain any required insurance from anyone you choose. You must obtain insurance for term of
loan covering security for this loan as indicated by the word "YES" below, naming us as loss Payee.
Physical damage insurance on vehicle listed under "Security" above, if "Y" appears under "Insured."
NOTICE: SEETHE FOLLOWING PAGES FOR ADDRIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING
ERRORS.
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ORIGINAL
Personal Credit Line Account Agreement (Page 2 of 3)
AVAILABLE CREDIT. You may obtain funds directly from us or through
your special checks up to your available credit. Each check must be
written far a least $100. Your available credit limit is your credit limit
(shown an page and less the total unpaid balance, including Finance
Charges, of your Account. If you make loan peyments by Check, we will
adjust your available Credit seven days after we receive your check to
allow lot check clewing. if you request funds 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) amount borrowed
under this Agreement; Ile) Finance Charges, Administrative Charges (the
late charge and bad check ehargel, and other charges provided in this
Agreement; (c) credit insurance charges, if any; (d) collection costs
permitted by applicable law, including reasonable attorneys' fees iii the
attorney is not our salaried employee); and (a) amounts in excess of
your credit limit that we may lend you, plus Finance Charges.
PAYMENT. You may repay your entire outstanding balance at any time
without penalty. You may not use your special cheeks to pay any
amounts due under this Agreement. Because the Finance Charge is
computed each day, you will contact us regarding the exact payoff
amount for the day you intend to make lull payment.
It you do not pay the endive unpaid belence on your Account at once,
you agree to pay at least the minimum payment shaven on your monthly
statement. 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 chock charge); Third, to any unpaid
credit insurance charges; and Fourth, to the unpaid outstanding be lance
of your Account. Any pert 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 pert of yaw 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 III the greater of $25 or the
Variable Payment Amount (as described below) plus any Administrative
Charges and credit insurance charges, rounded to the nearest $1; or (2)
the Finance Charges due for the billing cycle plus any Administrative
Chwges and credit insurance charges; or (3) the amount of the Annual
Fee assessed to your Account. In each instance the Minimum Monthly
Payment will be adjusted to include any unpaid amounts due from
previous billing cycles.
The Variable Payment Amount depends on the monthly periodic rate
than applicable to your Account, and is calculated as follows:
Monthly Periodic Rate Variable Psymsat Ameeet
through 1.33% 1.43% of Account Balance
over 1.33% through 1. 45% 1.55% of Account Balance
over 1.45% through 1. 67% 1.87% of Account Bafence
over 1.57% through 1. 70% 1.80% of Account Balance
over 1.70% through 1. 83% 1.93% of Account Balance
over 1.83% through 1. 95% 2.00% of Account Balance
over 1.95% 2.15% of Account Balance
FINANCE CHARGE. The Finance Charge is the Interest charged on the
balance of your Account during each billing cycle. The Finance Charge is
calculated from the date that each advance, chock or charge is posted to
your Account. The Finance Charge is computed by multiplying the average
daily balance in your Account in each billing cycle times the monthly
periodic rte. The avenge daily balance is determined by totaling all
daily unpaid balances in each billing cycle and dividing the total by the
number of days in that cycle but not less than 30). A daily unpaid balance
is the amount owed each day, excluding any unpaid Finance Charge,
Administrative Charges, and credit insurance charges for prior billing
cycles.
VARIABLE RATE.You agree that the monthly periodic an. used in
determining your Finance Charge will be a variable rate which may
change from month to month. The monthly periodic rate will be
one-twelfth of the sum of the Prime Rata plus the number of
percentage points es slated in the "Mere in" box an page one. The
Prime Rate applicable to any billing cycle will be the prime rate
published in "The Well Street Journal", a business newspaper, on the
first publication day of the month in which the billing Period begins. If
A range of raise is published, we will use the highest of the rates in
the range. When a change in the Prime Rate is published, a change in
the monthly periodic rate will take effect on the first day of the first
complete billing cycle following the date of the published change. The
new rate will apply to new loans and charges, and to the existing
balance of your account.
The initial monthly periodic rata on your Account Is shown on page
ono. The monthly periodic rate will not exceed that permitted by
applicable law. If circumstances such as a change in the law, any court
ruling or discontinued publication of the index do not Parma us to
continue use of this variable rate index, we will change the index
according to the procedure set out below in "Termination and Changes
in the Agreement.' An increase in the Prime Rate may increase the
Annual Percentage Rate leorresponding to the monthly periodic rate) and
the minimum payment on your account.
ANNUAL FEE. You agree to pay an Annual Fee as stated on page one for
participation in this revolving credit plan. The Initial Annual Fee is stated
on page one and is due and payable on the date that your Account Is
established, and the subsequent Annual Fee stated on page one is due and
payable on the some day of each subsequent year. You agree that this fee
may be Charged to your Account balance.
BAD CHECK CHARGE. If you pay by a check which is returned for any
reason, you will pay a bad check charge of $20.
LATE CHARGE. If you do not pay any required Minimum Monthly Payment
within 15 days 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).
OTHER CHARGES. You also agree to pay any amounts actually incurred by
Lender for services rendered In connection with the Personal Credit Line
Account for lees paid to public officials in connection with 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
sherd 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 quafify 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. Toe may
prohibit the stories of soeb Information (except far the sharing of
foremasts. bad treseactisns sr assailants. between on and you) by son/Ins
a wribn lagoon which cestdn year fell name, Social Secority Number and
shirting to oo M P.O. Box 1547, Chesapeake, VA 23320.
If you fail to fulfill the terms of your credit obligation, a negative report
reflecting on yaw credit record may be submitted to a Cred'n Reporting
Agency. You agree that the Department of Motor Vehicles lot 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 CNANGES IN THE AGREEMENT. We oar choose the terms of this
Asr.emolk 1811,9152 Increasing year Minimum Monthly Poysept and Increasing
He 06,01801 few of Flooce Charge, dring go 52nsal fee mad/sr fees if
permitted by applicable law, or change the Variable Note lodes, at any time.
Prier mature notice will be provided to yon rkes required by applicable law
onless Tog consent to do change before that limes. Chea0es may apply to ban
saw sea udstsading balances eelean prohibited by applicable law. However,
termination of your credit limit will occur only as provided in the "Default
and Cancellation of Agreement" paragraph. Balances outstanding untler this
Agreeemnt when the credit limit is reduced or terminated will continue to
accrue interest at the variable contract rate until paid in full.
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 and to cancel your credit privileges under this Agreement
because of (el fell.. to marks any payment in full when it is due under this
Agreement; to) frequent overdrawing of your line of credit; Ic) failure to
supply us with any information requested; (dl supplying us with misleading,
false, Incomplete Or incorrect information; lei breaking any of the promises,
terms or conditions that are contained in this Agreement; IN the filing of a
bankruptcy petition by or against you, (gl the death of any borrower who
signs this Agreement. After default, you will pay our court costs, reasonable
attorney fees of attorney is not our salaried employed. and other collection
costs related to the default, if not prohibited by applicable law. You may be
awarded reasonable attorney's fees it you prevail in an anion against us. In
the event your credit privilege is cancelled, we have the right to convert
your Account to a fixed rate of interest which shall be no higher than the
variable [correct rate in affect at the time of conversion.
YOUR BILLING RIGHTS. KEEP THIS NOTICE FOR FUTURE USE. This notice
contains important information about your rights and Lender's
responsibilities under the Fair Credit Billing Act.
Notify Lawlor In Case or Errors w asastlses About year Bill: If you think yo.
bill is wrong, at if you ;rood more information about a transaction on your
bill, write Lender on a separate sheet at the address listed an your bill after
the words: "Send your billing error notice tar: (Lender's name and address)."
Write to Lends, as soon as possible. Lender must hear from you no later
than 00 days after Lander sent you the first bill on which the .ror or
problem appeared. You can telephone Lender, but doing so will not preserve
your rights. In yaw Isitar, give Lander the ;allowing information, a Your
name and account numb. The dollar amount of the suspected error m
Describe the error and explain, it you can, why you believe there Is an error.
If you need morn information, describe the item you are not sure about.
Year NOW sad Leader's Respeesibilities After Leader Receives Your mines
Notice. Lander must acknowledge your letter within 30 days, unless Lander
has corrected the error by than. Within 90 days, Lender must either
correct the error or explain why Lender believes the bill was correct.
NOTICE: SEE THE FOLLOWING PAGE FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING
ERRORS.
03-01-00 ilflnlltlll?l?ltall?l?®?I1111nnI?iB?IIIII?I??gIIII?B?????l?llllllllllllllllll PA056672
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Personal Credit Line Account Agreement (Page 3 of 3)
After Lender receives your letter, Lander cannot try to collect any amount you question, or report you as delinquent. Lander can continue to bill you for the
amount you question, including finance charges, and Lander 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 Lander made a mistake on your bill, you will not have to pay any finance charges related to any questioned amount. It Lander did
not make o mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either
case, Lander will send you a statement of the amount you owe and the data that it is due.
If you fail to pay the amount that Lender thinks you owe, Lender may report you as delinquent. However, if Lander', explanation does not satisfy you
and you write to Lender within tan days telling Lander that you still refuse to pay, Lander must tell anyone Lander reports you to that you have e
question about your bill. And tender 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 tollow these rules, Lender can't collect the first $50 of the questioned amount, even if your bill was correct.
ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDER. The terms of the Arbitration Agreement end any other Riders signed as part of this loan
transaction are incorporated into this Agreement by reference.
APPLICABLE LAW. The terms and conditions of this Agreement will be governed by the provisions of the Pennsylvania Consumer Discount Company
Act, Chapter 7, Sections 6201 through 6221, Purdon's Pennsylvania Statutes Annotated, particularly Section 6217.1.
Before s.iQning this Agreement, you have road and received this Agreement and the Federal Truth-in-Lending disclosures
contained on it.
You, the customer(s) signing below, agree to observe the terms and conditions of this Agreement.
This loan is governed by the Pennsylvonis Consumer Discount Company Loan Act and applicable Federal law
/C, l?Qilrt?4? (SEAL)
Customer Signature
(SEAL)
Customer Signature
Date' 7 -.,) 7'd`y Date:
Witness: (SEAL) Witness:
03-Dl-00
RL VP NRE
(SEAL)
PA066673
Ifn?110?>Illn?l>Ilnnl?lmll>?1111111nIV>II>?I?IINI?IIIIIII?I??Inllllllllll?®???I?II?P?II
aC47E91D2BDS6RLA9000PA0566730ekCAWBELL a ORIGINAL
VERIFICATION
Dawn Richt, Recover Specialist for
HOUSEHOLD SINANCE CONSUMER DISCOUNT COVDANY
Deposes and says subject to the penalties of 18 Pa C.S. Section 4904 relating to unswom
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
? c Q
Y ?
44-
-L
_, V)
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-00555 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS
CAMPBELL DEBRA R ET AL
ROBERT BITNER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CAMPBELL DEBRA R A/K/A DEBRA R DAVIS the
DEFENDANT , at 1050:00 HOURS, on the 1st day of February , 2006
at 427 NORTH PITT STREET
CARLISLE, PA 170
DALE CAMPBELL, HUSBAND
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 18.00
Service 4.40
Affidavit .00
Surcharge 10.00
.00
32.40
Sworn and Subscribed to before
me this day of
JA.._ JuO (P n A.D.
by handing to
So Answers:
R. Thomas Kline
02/02/2006
CHROMULAK & ASSOCIATES
By : T J)
y
D 1U?'
r
Deputy -Sheriff
iff
Prota r
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CERTIFICA'T'E OF SERVICE
V.
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Defendan t.
CERTII"'ICATE Of SERVICE
I ceniify under penalty ofpez ury under the laws of the State of PeaNSy/o,'Amthat, on the date
stated below, I did the following:
On the 5 'V day of February , 200 4, I (strike out what doesn't
apply) mailed by Mail, postage prepaid I hand deli-Famd a true copy of the
ANSWER. AFFIRMATIVE DEFENSES ANA COUNTI;RCI AIM5 [name of paper servedl filed,
S4ssa C,
in this mattor too. F `n 1f$[Name of ptaint;ff or plaintiff's Attomoyl at the following address: _
3'lf So??k o_'af¢ 3ooUver-d OGcioitj- bcr?jPr?-15517
Dated this, 5 'k day of February -,2004-in C a1 ?co l?, i Lk-
(Signature) A 1,A uQex4? t2 dpi
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TO: T-65zz if, mai,+6
AND TO: Clerk of the Court
YOU AND EACH OF
in the above-entitled cause am
original process, be served upc
Rule 5.
Dated this _
NOME OFAPPEXPUNCE-Page l
OF (omrnoi7 191za5
No. o U 5--3
NOTICE OF APPEARANCE
PlaintifRs),
Q?
Attorney for.Plaintiff
OU PLEASE TAKE NOTICE that Defendant(s) hereby appears
,quests that all further papers and pleadings herein, except
the Defendant at the address below stated, pursuant to Civil
+h day of E
'2004.
(Defendant's Signature)
lZ)abr'k 12 CctmfJhall /1lGR I?e.bra 2 C7avlS
(Print Name)
(Address)
?w?li5(-e , ?a, 17413
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nrtnm?s COURT OF C-? in g, o n I?l?-u J`
COUNJ'XOF C':n hr /G ?t /fan n14//vG tr1 ?G,
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ANSWER, AFFIRMATIVE DEFENSES
AND COUNTERCLAIMS
Ataintif?s),
V.
e
I. ANSWER
Defendant(s) answer the complaint as follows:
i . Admit the statements contained in paragraph numbers 1 3 b q
2. Deny the statements contained in paragraph numbers 9 d-k
ANSWER, AFFIRMATIVE DEFENSES AND COUNTERCLAIMS
Page I oft
Lack knowledge about the truth and therefore deny the statements contained in
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paragraph number(s) 5- 4
It. AFkTRMATIVE DEFENSES
Defendant(s) other defenses are: i ti 3 1^?i c_ 'zn i ?U d 5 d uu 4-v (ay 4 d(S
?4 vn.edi'ewl sabil 4,s5 - 5j+-e u Ff?:cl,<_e) k rcf5k?p IpcOr,4 kjo5,heO
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T (L COUNTERCLAIMS
Plaintiff owes defendant $ F because: 0? c0 ? 4 0c- 4-s 4 4No.r ru 5
Defendant(s) request that this lawsuit be dismissed and that a judgment be entered against
the plaintiff(s) for any counterclaims, costs, or attorney fees.
DATED this <1?n/ day of <eb
206k
A&4", le b?It
(signature) /-1teR?,r? a K a its
Name: t??lica /C y v? b e y
Address: q?? A.), ?'W-5t (o- liS /0a /7413
Telephone: 71) -d 5 / 9 39
4NSWFR, AFFIRMATIVE DEFErvSESAND COUNTERCLAIMS
Wage 2 oft
HOUSEHOLD ,INCOME AND EXSPENSES
I NCON E: (Net month!) 2? 5" 3 A
Your net monthly wages (including our pension/ Social Security) $19 9 31
Your Spouses net monthl wages (including our ension octal Secant ); ' $ `? 3 G c
Other $
Total monthly income $ 2?l t I Z
Food, Clothing and Misc. (including personal care roducts and supplies) $ cie, ec
Rent/mott a e and a taxes r? 7 b'. ? ea $ l e • / /c
Electric $ ?5.b0
Gas l{F? t $ r, oc
Oil $
Cable $ ')6"11
Telephone $ fir, o v
Water $ L,.oo
Car +?
5
a ?4r
$
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S..
4
Auto insurance $ S x, c e,
Gas -e ? ?g$ ') o_6e)
Tolls $
Health Care (medical Insurance and or medical payments) $ yc.GO
Court Ordered payments $ -
Child / D endent Care $
Child Support $ _
Alimon $ '
Life Insurance °$
Other Ex nses (Describebelow) L,l,eu ar eau $ A,00
Total Expenses $
I / we hereby certify that the information contained herein pertaining to my/ our
statement of assets, liabilities and other information is true and accurate to the best of
our knowledge.
I / we further understand that if our financial condition changes, we shall inform
American Debt Negotiators in a timely manner.
I/ we further authorize American Debt Negotiators to disclose such information
contained herein to my/our creditors as may be necessary to effectively settle and or
negotiate our debts.
(Your signature)
(S uses signature)
01 '-06
Dated:
Dated:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 2006-00555
Plaintiff,
vs.
DEBRA R. CAMPBELL
a/k/a DEBRA R. DAVIS,
Defendant.
Plaintiffs Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
427 N. PITT STREET
CARLISLE, PA 17013
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
TYPE OF PLEADING:
Reply to New Matter and Answer to
Counterclaim
TYPE OF CASE:
Civil Action
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
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, LLC
375 Southpointe Boulevard
41h Floor
Canonsburg, PA 15317
(724) 916-2400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
No. 2006-00555
Plaintiff,
vs.
DEBRA R. CAMPBELL
a/k/a DEBRA R. DAV IS,
Defendant.
REPLY TO NEW MATTER
AND NOW COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY, by its Attorneys, Chromulak & Associates, LLC, with its Reply to
New Matter, the following of which is a statement thereof:
1. Denied. After reasonable investigation, Plaintiff is without knowledge or
information sufficient to form a belief as to the truth of the averments in Paragraph 4 of
Defendant's New Matter, which averments are, accordingly, denied.
WHEREFORE, Plaintiff requests that judgment be entered in its favor and against the
Defendant.
ANSWER TO COUNTERCLAIM
AND NOW COMES, the Plaintiff, HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY, by its Attorneys, Chromulak & Associates, LLC, with its Answer to
Counterclaim, the following of which is a statement thereof:
1. Denied. Defendant fails to state a claim for which relief can be granted.
WHEREFORE, Plaintiff requests that Defendant's Counterclaim be dismissed and
judgment entered in Plaintiff's favor against the Defendant.
Respectfully submitted,
Chromulak & Associates, LLC
By: JU y 91921aK
CATHY N CHROMULAK, ESQ.
LORI M. DIRENZO, ESQ.
NANCY C. WILKINS, ESQ.
JESSA C. MARTIN, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
0 Floor
Canonsburg, PA 15317
CERTIFICATE OF SERVICE
I, counsel for Plaintiff, HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY, hereby certify that a true and correct copy of the foregoing REPLY TO NEW
MATTER AND ANSWER TO COUNTERCLAIM was served upon the following by United
States First Class Mail, postage prepaid on this ?? day of 2006:
DEBRA R. CAMPBELL a/k/a DEBRA R. DAVIS
427 N. Pitt Street
Carlisle, PA 17013
i
Cathy Ann Chromulak, Esquire
Lori M. DiRenzo, Esquire
Nancy C. Wilkins, Esquire
Jessa C. Martin, Esquire
C?
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
PLAINTIFF,
V.
DEBRA A. CAMPBELL
a/k/a DEBRA R. DAVIS,
CIVIL DIVISION
No. 2006-00555
TYPE OF PLEADING
PRAECIPE FOR ARBITRATION
TYPE OF CASE
DEFENDANT
PLAINTIFF'S ADDRESS
2700 SANDERS ROAD
PROSPECT HEIGHTS, IL 60070
DEFENDANT'S ADDRESS
427 N. PITT STREET
CARLISLE, PA 17013
CIVIL ACTION
FILED ON BEHALF OF
HOUSEHOLD FINACNE CONSUMER
DISCOUNTCOMPANY
COUNSEL OF RECORD
CATHY ANN CHROMULAK, ESQ.
PA ID NO 42067
NANCY 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, 4T" FLOOR
CANONSBURG,PA 15317
(724) 916-2400
THIS IS AN ATTEMPT TO
COLLECT AT DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
No. 2006-00555
Plaintiff,
VS.
DEBRA A. CAMPBELL
a/k/a DEBRA R. DAVIS,
Defendant.
PRAECIPE FOR ARBITRATION
TO THE PROTHONOTARY:
Please place the above-captioned case on the next available Arbitration List.
i
BY
Cathy Ann hromulak, Esq.
Nancy Wilkins, Esq.
Jessa C. Martin, Esq.
Amy L. Sabolchick, Esq.
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
THIS IS AN ATTEMPT TO
COLLECT AT DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
CERTIFICATE OF SERVICE
I, Amy L. Sabolchick, counsel for HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing
Praecipe for Arbitration was served, via United States First Class Mail, postage prepaid, on
the following, this I day of ( v 2006:
DEBRA A. CAMPBELL
a/k/a DEBRA R. DAVIS
427 N. Pitt Street
Carlisle, PA 17013
`!n 99
lCi! ?? ( iZL/?G
Amy T 1 abolc 'ck
THIS IS AN ATTEMPT TO
COLLECT AT DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
d ?
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31
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
CIVIL DIVISION
NO. 2006-00555
VS.
DEBRA A. CAMPBELL
a/k/a DEBRA R. DAVIS,
Defendant.
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
ANNA BONARRIGO, counsel for the plaintiff in the above action, respectfully
represents that:
1. The above-captioned action is at issue.
2. The claim of the plaintiff in this action is $9,536.85.
The counterclaim of the defendant in this action is $0.00
The following attorney(s) are interested in the case as counsel or are otherwise
disqualified to sit as arbitrators: Anna M. Bonarrigo, Esq.
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3)
arbitrators to whom the case shall be submitted.
Respecfully submi
Cathy Ann Clwomulak, Esq.
Amy L. Sabolchick, Esq.
Anna M. Bonarrigo, Esq.
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
(724) 916-2400
THIS IS AN ATTEMPT TO
COLLECT AT DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION
DISCOUNT COMPANY,
NO. 2006-00555
Plaintiff,
VS.
DEBRA A. CAMPBELL
a/k/a DEBRA R. DAVIS,
Defendant.
ORDER OF COURT
AND NOW, 0 Cbgm U l , 20 0(0 in consideration of the
foregoing petition, C ? , Esq., OUIV, Es and OA,,k J hereby appointed arbitrators in the above captions action as prayed for.
By thQV' P. .
THIS IS AN ATTEMPT TO
COLLECT AT DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE
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HOUSEHOLD FINANCE CONSUMER, IN THE COURT OF COMMON PLEAS OF
DISCOUNT COMPANY, CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF
V.
DEBRA R. CAMPBELL a/k/a
DEBRA R. DAVIS,
DEFENDANT
06-0555 CIVIL TERM
ORDER OF COURT
AND NOW, this ?day of December, 2006, the appointment of David A.
Baric, Esquire, to the Board of Arbitrators in the above-captioned case, IS
VACATED. Robert Dailey, Esquire, is appointed in his place.
By the Court,
Edgar B. ayl , J.
Edward L. Schorpp, Esquire
Chairman
Robert Dailey, Esquire
Court Administrator
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Plaintiff
4"
Defendant
In The Court of Common Pleas of Cumberland
County, Pennsylvania N4Z 46
Civil Action - Law.
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United
States and the Constitution of this C onwealth and that a ill discharge the duties of our office
with fidelity.
Signature Signature Signature
Name (Chairman) Name I Name
Law Firm Law Fi?'rrn Law Firm
.31T- S.
Address
T
Address
r
city, zip
c5;etrsCE /moo/"?
city, zip
Address
City, Z*%
Award
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
F/w,? ?AI !E':2V t z Off" .09..Vb 0096r',091NS7-
e_?_ -S
. Arbitrator, dissents. (Insert name if applicable.)
Date of Hearing: 6 - / 3 --Q
Date of Award:-6-/3-0 7
Notice of Entry of Award
Now, the _ag+? day of , 20_pl_, at S:59 , A M., the above award was
entered upon the docket and notice thereof given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $ 350. Do
By:
/rothonotary Deputy
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
PLAINTIFF,
VS.
DEBRA R. CAMPBELL A/K/A DEBRA
R. DAVIS,
CIVIL DIVISION
No. 2006-00555
TYPE OF PLEADING:
PRAECIPE FOR JUDGMENT ON
ARBITRATION AWARD
DEFENDANT.
TYPE OF CASE:
CIVIL ACTION
FILED ON BEHALF OF PLAINTIFF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK PA ID NO. 42067
MAUREEN A. DOWD PA ID NO. 90549
CHRISTINE A. SAUNDERS PA ID NO. 203373
BETH ARNOLD HOWELL PA ID NO. 203606
CHROMULAK & ASSOCIATES, L.L.C.
375 SOUTHPOINTE BOULEVARD
4TH FLOOR
CANONSBURG, PA 15317
(724) 916-2400
R.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY, CIVIL DIVISION
PLAINTIFF, No. 2006-00555
Vs.
DEBRA R. CAMPBELL A/K/A DEBRA R. DAVIS,
DEFENDANT.
PRAECIPE FOR JUDGMENT ON ARBITRATION AWARD
TO: PROTHONOTARY
Enter judgment on the arbitration award in the above entitled case against DEBRA
R. CAMPBELL a/k/a DEBRA R. DAVIS in the amount of $13,243.10 at the rate of 6% per
annum, together with additional costs of suit.
RESPECTFULLY SUBMITTED,
JULY 30, 2007 ?eth
CATHY ANN CHROMULAK PA ID NO. 42067
MAUREEN A. DOWD PA ID NO. 90549
CHRISTINE A. SAUNDERS PA ID NO. 203373
BETH ARNOLD HOWELL PA ID NO. 203606
CHROMULAK & ASSOCIATES, L.L.C.
375 SouTHPoINTE BOULEVARD
4TH FLOOR
CANONSBURG, PA 15317
(724) 916-2400
Attorneys for Plaintiff
?OVsdMdGlD ?w/.q?/??
6 ? ft ere ®' S -C Plaaigntif ff l
Defendant
In The Court of Common Pleas of Cumberland
County, Pennsylvania Novi 6
Civil Action - Law.
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United
States and the Constitution of this C monwealth and that a ill discharge the duties of our office
with fidelity. % (, ?E
Signature Signature Signature
Name (Chairman) Name I Name
til 4
Law Firm
31T- S. DQ
Address
d!?/CN??'jPiL?SG!/tRGR k?olev ?J?(Gq&l
Law Firm Law Firm /G/'
Address
Y
City, zip
? ?aoat?
Award
City, Zip
-#gQ900b030
Address
(f 9 jr- Its h P-,? 17701
City, Zip
* 184at
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Note: If damages for delay are awarded, they shall be separately stated.)
,f?iS?E' Tj???.,/QA??/T , T,?? ?od.?T 17.x' /3. ?•?.1D. aas
. Arbitrator, dissents. (Insert name if applicable.)
Date of Hearing: 6 -/ 3 -Q 7
Date of Award: 45?'-/ 3-Q 7
Notice of Entry of Award
Now, the day of ,Jljnp , 20 , at 8: 59 , A M., the above award was C
entered upon the docket and notice thereof given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: $,
rothonotary
3w. 00
By:
Deputy
C*l
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
CIVIL DIVISION
No. 2006-00555
Plaintiff,
VS.
DEBRA R. CAMPBELL a/k/a
DEBRA R. DAVIS,
TYPE OF PLEADING:
PRAECIPE FOR A WRIT OF
EXECUTION
Defendant,
and
PNC BANK,
Garnishee.
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
Defendant's Address:
427 NORTH PITT STREET
CARLISLE, PA 17013
Garnishee's Address:
105 NOBLE BLVD.
CARLISLE, PA 17013
Date: August 9, 2007
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
FILED ON BEHALF OF:
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
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
. , .#
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
DEBRA R. CAMPBELL a/k/a DEBRA R. DAVIS,
Defendant,
and
PNC BANK,
Garnishee.
CIVIL DIVISION
No. 2006-00555
PRAECIPE FOR WRIT OF EXECUTION
TO: The Prothonotary
Please issue a Writ of Execution in the above matter,
1. directed to the Sheriff of CUMBERLAND County;
2. against DEBRA R. CAMPBELL a/k/a DEBRA R. DAVIS, defendant, and
3. against PNC BANK, garnishee,
4. and index this writ
a. against DEBRA R. CAMPBELL a/k/a DEBRA R. DAVIS, defendant, and
b. against PNC 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 an accounts individual and
joint, personal and business.
5. 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.
$13,243.10
$ 15.47
$13,258.57
CATHY ANN CHROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
BETH ARNOLD HOWELL, ESQ.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N006-555 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HOUSEHOLD FINANCE CONSUMER DISCOUNT
COMPANY Plaintiff (s)
From DEBRA R CAMPBELL A/K/A DEBRA R DAVIS, 427 NORTH PITT STREET,
CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of PNC BANK, 105 NOBLE BLVD. CARLISLE, PA 17013 - SAID WRIT OF EXECUTION IS
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$13,243.10
Interest $15.47
Atty's Comm %
Atty Paid $143.90
Plaintiff Paid
Date: AUGUST 14, 2007
(Seal)
L.L.$.50
Due Prothy $2.00
Other Costs
Curtis R. Long, Prothonotary
By:
&? ? &v2jj
Deputy
REQUESTING PARTY:
Name BETH ARNOLD HOWELL, ESQ.
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. 203606
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-00555 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD FINANCE CONSUMER
VS
CAMPBELL DEBRA R ET AL
And now RICHARD SMITH
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0008:47 Hours, on the 16th day of August , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
CAMPBELL DEBRA R A/K/A DEBRA R DAVIS
hands, possession, or control of the within named Garnishee
PNC BANK 105 NOBLE BLVD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
VIOLA ORLELKE (ASST MANAGER)
, in the
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to Her-.
Sheriff's Costs: So answ
Docketing .00 r
Service .00
Affidavit .00 R_.' Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00 .00
08/17/2007
Sworn and Subscribed to
before me this
i
day of By
put Sheriff
A.D
?'
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
vs.
DEBRA R. CAMPBELL a/k/a
DEBRA R. DAVIS,
Defendant,
and
PNC BANK,
CIVIL DIVISION:
No. 2006-00555
TYPE OF PLEADING:
Praecipe to Discontinue
Against Garnishee ONLY
TYPE OF CASE:
Civil Action
Plaintiff's Address:
2700 Sanders Road
Prospect Heights, IL 60070
FILED ON BEHALF OF:
Defendant's Address:
427 NORTH PITT STREET
CARLISLE, PA 17013
Garnishee.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY
COUNSEL OF RECORD:
CATHY ANN CHROMULAK, ESQ.
PA ID NO. 42067
MAUREEN A. DOWD, ESQ.
PA ID NO. 90549
BETH ARNOLD HOWELL, ESQ.
PA ID NO. 203606
CHRISTINE A. SAUNDERS, ESQ.
PA ID NO. 203373
CHROMULAK & ASSOCIATES, L.L.C.
375 Southpointe Boulevard
4`h Floor
Canonsburg, PA 15317
(724) 916-2400
AOP
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
HOUSEHOLD FINANCE CONSUMER
DISCOUNT COMPANY,
Plaintiff,
VS.
DEBRA R. CAMPBELL a/k/a
DEBRA R. DAVIS,
Defendant,
and
PNC BANK,
Garnishee.
CIVIL DIVISION:
No. 2006-00555
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY
TO THE PROTHONOTARY:
Please discontinue this action against the above garnishee, PNC BANK, and mark the
docket accordingly.
Sworn to and subscribed
Before me this 25k day
of , 2007.
Respectfully submitted,
CHROMULAK & ASSOCIATES, L.L.C.
By: ?-)&kl
CATHY ANN CHROMULAK, ESQ.
MAUREEN A. DOWD, ESQ.
BETH ARNOLD HOWELL, ESQ.
CHRISTINE A. SAUNDERS, ESQ.
Attorneys for Plaintiff
375 Southpointe Boulevard
4th Floor
Canonsburg, PA 15317
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Heather L. Hatfield, Notary Public
° Cecil T
wp., Washington County
my D-4 mission Expires June 29,2oio
96oclRtion of Notaries.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
10
r?
CERTIFICATE OF SERVICE
I, counsel for HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, hereby
certify that a true and correct copy of the foregoing Praecipe to Discontinue Against Garnishee
Only was served upon the following by First Class Mail, postage prepaid on this 28TH day of
September, 2007.
PNC BANK
CHERYL HEINZ
FIRSTSIDE CTR., 500 FIRST AVE.
PITTSBURGH, PA 15219
DEBRA R. CAMPBELL a/k/a
DEBRA R. DAVIS
C/O ANDREW SHAW, ESQ.
200 S. SPRING GARDEN, STE. 11
CARLISLE, PA 17013
amidd &4vaL
Cathy Ann Chromulak, Esq.
Maureen A. Dowd, Esq.
Beth Arnold Howell, Esq.
Christine A. Saunders, Esq.
THIS IS AN ATTEMPT TO
COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL
BE USED FOR THAT PURPOSE.
00
.,p 00 l9 _ h7
w tf'1 v
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six'months.
Sheriff's Costs: __ Adv nwe Costs: 150.00
"'Sfi nri Os Costs 85.99
Docketing 18.00 64.01
Poundage 1.69
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 03/25/08
Mileage 4.80
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.00
TOTAL 85.99 ? Y14 f
So Answers,
Q
R. Thomas Kline, Sheriff
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