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Home My WebLink About06-0908IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. C>L-- 96P l.! Lal L?T/LI RODNEYSTROUP A/K/A RODNEY E. STROUP 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 CIVIL DIVISION BENEFICIAL CONSUMER DISCOUNT COMPANY, No. CD(o -Q? CtvL y? Plaintiff, vs. TYPE OF PLEADING: Complaint RODNEYSTROUP A/K/A RODNEY E. STROUP, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 64 PEACHY ANN DRIVE NEWVILLE, PA 17241 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: 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. PA ID NO. 201169 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 4"' Floor Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, p No. Plaintiff, VS. RODNEYSTROUP A/K/A RODNEY E. STROUP, 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. RODNEY STROUP A/K/A RODNEY E. STROUP is an adult individual residing at 64 PEACHY ANN DRIVE, NEWVILLE, PA 17241. 3. On or about MARCH 28, 2001, 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 MAY 20, 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 TEN THOUSAND SEVEN HUNDRED EIGI ITY-SIX AND 80/100 ($10,786.80) DOLLARS as of JANUARY 2, 2006. Numerous demands have been made upon Defendant by Plaintiff, but Defendant has failed or refused to pay. 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 TEN THOUSAND SEVEN HUNDRED EIGHTY-SIX AND 80/100 ($10,786.80) DOLLARS, with interest thereon at the rate of 24% from JANUARY 2, 2006, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC By: Alyj?;4? ?, 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 1 of 3) LENDER (called "We", "Us", "Our") BENEFICIAL CONSUMER DISCOUNT COMPANY 418 STONEHEDGE DRIVE SUITE 2 CARLISLE PA 17013 BORROWERS (called "You", "Your") STROUP, RODNEY SS# 201628143 64 PEACHY ANN DRIVE NEWVILLE PA 17241 LOAN NO. 711715-17-503182 OF AVEPACE DAILY BALANCE PERIODIC RATE IRATE: 01 AND OVER 2.000 % - 24.000 % # 5600 03/28/01 INITIAL ANNUAL SUBSEQUENT ANNUAL FEE FEE 00 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 ("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 Personal 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 may obtain any required insurance from anyone you choose and may assign any other policy of insurance you own to cover the security for this loan. You must have insurance 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". Physical damage insurance on othe der "Security"' above, if "Y" appears under "Insured". NOTICE SEETHE FOLLOWING PAGES FOR ADDITIONAL EXHIBIT RMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. 03-07-00 F NRE I?VIIII?II?I®IIII?IIIIIII?III?? III IN 111111111110 1111111111101 PAB56311 'rc1 NS MA01D62199RLA9000PAB563110 ORIGINAL Perb?nal Credit Line Account Agreement (Pa, 1 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 for at least S1(0.DO. Your available credit is your credit limit (shown an page one) less the total unpaid balance, including Finance Charges, of your Account. If you make loan payments by cheek we will adjust your available credit seven days after we receive your check to allow for check clearing. If you request funds in en amount that would cause you to exceed your available credit, we are not obligated to honor your request. If we do land you an amount over your available credit, you agree to pay us that excess amount, plus Finance Charges and Over the Credit Limit Charges, it any, immediately. PROMISE TO PAY. You promise to pay Lender: (a) amounts borrowed under this Agreement; (b) Finance Charges, Administrative Charges flee charge, bad cheek charge, and over the credit limit charge), and other charges provided in this Agreement; (c) credit Insurance charges, If any; (d) collection costs permitted by applicable law, including reasonable attorneys' fees; and (e) amounts In excess of your credit limit that we may lend you. PAYMENT. You may repay your entire outstanding balance at any time without penalty. You may not use your special checks to pay any amounts due under this Agreement, Because the Finance Charge is computed each day, you will contact us regarding the exact payoff amount for the day you intend to make full Paymem, If you do not Pay the entire unpaid balance on your Account at once, you agree to pay at least the Minimum Payment shown on your monthly statement. PAYMENT AMOUNT. The monthly repayment amount, consisting of Finance Charge and Principal, necessary to completely repay the Principal Balance and applicable Finance Chugs during the time period represented by the Payment Factor Indicated below, assuming no additional advances are taken. Your initial Payment Amount is calculated using the Payment Factor shown below. Every time you take an additional cash advents, the Payment AMC" on your Account will be recalculated using the Payment Factor shown below. Once Yom Payment Amount is determined, this amount will remain fixed for subsequent billing periods until a new advance is posted to your account. When this occurs, your Payment Amount will be recalculated based an the Payment Factor of the new Principal balance. PAYMENT FACTOR. The time period in months during which, if each Payment Amount is paid on the Due Date specified on the billing statement, the Principal Balance and applicable Finance Charge will be fully repaid. The appropriate Payment Factor is determined with reference to the following schedule. Pr1alPal Payment Balance factor (months) $O - $2,500 30 $2,501 - $5,000 so $5,001 - 510,000 72 $10,001 - $15,000 80 MINIMUM PAYMENT. The Minimum Monthly Payment for any billing cycle will be the greater of $25 or the Payment Amount (es described .bevel Pius any Annual Fee, Insurance Charges, Administrative Charges and any amounts past due. APPLICATION OF PAYMENTS. Yom payments on this Account are applied in the following order, (a) past due insurance charges, if any, lb) pest due Finance Charge, Ic) past due additional charges such as Bad Check Charges, if any, la) past due Principal, bl currently due insurance Charges, If any, (N Currently due Finance Charge, (g) currently due additional charges such as Bad Check Charges, if any, IN currently tlue Principal. FINANCE CHARGE. The Finance Charge is the Internet charged on your Account during each billing cycle. A Finance Charge Is calculated from the data that each advance, check or chorea is posted to your Account. A Finance Charge is Computed by multiplying the average dally balance in your Account in each billing cycle times the monthly periodic rate. The average 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. 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. SECURITY. You agree to give us a security interest in the property iderttifined on papa one, which will seems all indebtedness, including future advances under this Agreement. ANNUAL FEE. You agree to pay an Annual Fee for participation in this revolving credit plan. The Initial Annual Fee stated on page one Is due and payable on the date that your Personal Credit Line Account is established and the Subsequent Annual Fee stated on page one is due and payable on the same day of each subsequent year. You agree that these charges may be charged to your Account Balance. BAD CHECK CHARGE. You will pay a fee of $20 If any payment check is returned because of insufficient fund. or is otherwise dishonored. You agree that Lander may deduct this charge from e monthly payment. LATE CHARGE. It you do not pay the Minimum Peymant within 15 days after the due time shown on your billing statement, we will charge you a late charge equal to the greater of 10% of the payment amount or $20.00. OVER THE CREDIT LIMIT CHARGE. We may charge you $25.00 if you issue a special check for which you do not have sufficient available credit and which is retuned to us by the bank on which it is der". OTHER CHARGES. You agree to pay any amount actually incurred by us in connection with the Personal Credit Line Account for personal property taxes and recording and release fees. You agree that those 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 me stores. other lenders, and credit reporting agencies. You authorize us to share any information, an a regular basis, we obtain related to your Account, including but not limited to credit reports end insurance information, with any of ow 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 sherles of such Information (except for the sharing of Informative oboe transactions m experiences between at Suit yen) by studied a written request welch contains your fell ume, Social Secorlty Number and Address to as st P.D. Be. 1547, Chesapeake, VA 22220. 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 for your stma's equivalent of such department) may release your residence address to us, should it become necessary to looms 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 cam terminate vs., right to obtain aUttlaal advances or tMgs the terms of this Agrsamaat, bringing Isersating the rote of Fiance Charge at any time. Prier written notice will be previded to you whom ragaired by applicable law saless yon consent to thn thud before that time. Chooses may apply to bath Be. and Outstanding Yellen, "less prohibited by nPpllcvkla 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 and to cancel your credit Privileges under this Agreement because of (a) failure to make any payment in full within 30 days after due under this Agrmament; (b) frequerd overdrawing of your line of credit; (e) failure to supply us with any information requested; 40 supplying us with misleading, false, incomplete or Incorrect Information; le) breaking any of the promises, terms or conditions that are contained in this Agreement; 10 the filing of a bankruptcy petition by or against you; 101 the death of any borrower who signs this Agreement. After default, you will pay our curt cotta, reasonable attorney fees (if attorney is not our salaried employee), and other collection costs related to the default, if not prohibited by applicable law. You agree that, should we obtain judgment against you, a portion Of your disposable earnings may be attached or garnished (paid to us by your employer), as provided by Federal 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. You spree to pay Interest on any judgment at the contract rate. YOUR BILLING RIGHTS. KEEP THIS NOTICE FOR FUTURE USE. This notice contains important information about your rights and Lander's responsibilities under the Fair Credit Billing Act. Notify Lad., Is Ent, of Errors or overdose About Year gill. 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 vow bill after the words: "Send your billing error notice to: (Lender's name and addressl." Write to Lender as soon as possible. Lender must hear from you no later than 60 days after Lander sent you the first bill on which the error or problem appeared. You can telephone Lander, but doing so will not preserve your rights. In your letter, give Lender the following information 1) Yom name and account number 2) The dollar amount of the suspected error 31 Deseribe the error and explain, if you tan, why you believe there is an error. If you need more information, describe the item you are not ume about. - NOTICE: SEE THE FOLLOWING PAGE FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TD DISPUTE BILLING ERRORS. C3-0-00 F NRE onoceatn I114u, W On IIIIII IIII11111 ? II? IEII ?IIC ?v iWllll? III W ? IIII I®I IIW IIIIIII IIII ?I ?? I? NS14ADID62 199RLA9000PA9563120xxSTROUP x ORIGINAL Personal Credit Line Account Agreement (Page 3 of 3) Year Rights nod tender's Responsibilities After Leader Receives Your Written Hallse. Lender must acknowledge your letter within 30 days, unless Lander has corrected the error by then. Within 90 days, Lender must either correct the error or explain why Lender believes the bill was correct. Aker 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 Lender can apply any unpaid amount against your credit limit. You do not he" to pay any questioned amount while Lander is investigating, but you we still obligated to pay the parts of your bill that are not in question. If Lender finds that Lender made a mistake on your bill, you will .I have to pay any finance charges related to any questioned amount. If Lender did not make a mistake, you may have to pay finance charges, and you will have to make up any missed payments on the questioned amount. In either case, Lender will send you a statement of the amount you owe and the date that it is due. If you fail to pay the amount that Lender thinks you owe, Lender may report you as delinquent. However, if Lender's explanation does not satisfy you and you write to Lender within ten days telling Lander that you still refuse to pay, Lender must tell anyone Lender reports you to that you have a question about your bill. And, Len der must tell you the name of anyone Lander reported you to Lender must tall anyone Lender reports you to that the matter has been settled between us when it finally is.lf Lander doesn't follow these rules, Lander can't collect the first $50 of the questioned amount, even if your bill was correct. If Lender doesn't follow these rules, Lender can't collect the first $50 of the questioned amount, even if your bill was correct. ALTERNATIVE DISPUTE RESOLUTION AND OTHER RIDER. The terms of the Arbitration Agreement and any other Riders signed as part of this loan transaction are incorporated into this Agreement by reference. APPLICABLE LAW. The 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, Portion's Pennsylvania Statutes Annotated, particularly Section 6217. Before signing this Agreement, you have read and received this Agreement and the Federal Truth-In-Lending disclosures contained in it You, the customer(s) signing below, agree to observe the terms and conditions of this Agreement. (SEAL) Cac or Signat f Date: Witness: J? (SEAL) 03-01-00 F NRE 1111111111111111111 III 111111101111111 xS14AOID62199RLA9DOOPA8563130"xSTROUP Customer Signature Date: Witness: (SEAL) PABS6313 11 qll ICI I??? III 111 IVII 101 11 1II III I III ORIGINAL VERIFICATION Dawn Richt, Recover Specialist for BENEFICIAL CONS17MER DISCOUNT 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 (q SHERIFF'S RETURN - REGULAR CASE NO: 2006-00908 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS STROUP RODNEY AKA RODNEY E STR CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STROUP RODNEY AKA RODNEY E STROUP the DEFENDANT , at 0816:00 HOURS, on the 21st day of February , 2006 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE RODNEY E STROUP by handing to 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 .39 Affidavit .00 Surcharge 10.00 .00 28.39 Sworn and Subscribed to before me this /. day of ov(a A.D. rothon ry So Answers: . f ., R. Thomas Kline 02/21/2006 CHROMULAK & ASSOCIATES By : / D p ty Sh i iff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. RODNEY STROUP aJk/a RODNEY E. STROUP, Defendant. Plaintiffs Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 64 PEACHY ANN DRIVE NEWVILLE, PA 17241 Dated: MARCH 27, 2006 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 06-908 - 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 AMY L. SABOLCHICK, ESQUIRE PA ID NO. 94653 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4m Floor Canonsburg, PA 15317 (724) 916-2400 TO: PROTHONOTARY Please enter judgment by default against the within-named defendant, RODNEY STROUP alk/a RODNEY E. STROUP, for failure to file an Answer as follows: with additional costs of suit. II CATHY ANN CHRO ULAK,ESQUIRE 01yT M. DI RENZO, ESQUIRE NANCY C. WILKINS, ESQUIRE JESSA C. MARTIN, ESQUIRE AMY L. SABOLCHICK, ESQUIRE Attorneys for Plaintiff Amount Claimed in Complaint: $10,786.80 Interest from 1/03/06 through 3/27/06: 425.86 Costs of Collection through 3/27/06: 492.89 TOTAL $11,705.55 With interest accruing on the total balance of $11,705.55 at the rate of 6% per annum, together 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 ersigned an ority, a Notary Public in and for said County and State, personally appeared,] ESQUIRE, attorney for and authorized representative of plaintiff who, being duly sworn according to law, deposes and says that the defendant is not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed to defendant on MARCH 14, 2006 by certificate of mailing in accordance with Pa.R.C.P, 237. 1, as evidenced by the attached copy, CATHY CHROMULAK, ESQUIRE LORI M. DI RENZO, ESQUIRE NANCY C. WILKINS, ESQUIRE JESSA C. MARTIN, ESQUIRE AMY L. SABOLCHICK, ESQUIRE Sworn to and subscrib d be re me This 2U day of _IX&&? 2006. . "I J 0" THIS IS AN ATTEMPT TO WEALTH OF P?NN?SYLVANIA Notarial SCI COLLECT A DEBT AND ANY MdWeLWnhla.N0taryPdit INFORMATION OBTAINED WILL Ce `rm. %"ese"+oton BE USED FOR THAT PURPOSE. YComme<=-? uw,?.3Ury7,2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, No. 06-908 CIVIL TERM Vs. RODNEY STROUP AKA RODNEY E. STROUP, Defendant(s). TO: RODNEY STROUP AKA RODNEY E. STROUP 64 PEACHY ANN DRIVE NEWVILLE, PA 17241 DATE OF NOTICE: MARCH 14, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 OR 8004CA.QCHR/0AM'ULAK, 990918By: ESQ. LORI M. DIRENZO, ESQ. NANCY C. WILKINS, ESQ. JESSA C. MARTIN, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard e Floor Canonsburg, PA 15317 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .N O 3 m v V e m V1 A W N -? O t0 W -1 m to A W N n z ? Y c ^ ? 3 p a -? a :h rn r ? v ? W N .,y -. ? J D w z a3 ( i m atn ?? ti ?„ n ~ n0 9C] b7 ?m p p C m?Hx ? v 9z0 eH cnH cd ?' ay Jm 3 002v 8m b9 ?p0 y C? z "o ?x 'F ? ?y ' H W yzmr x C9 7 9 m? r O 09 N (n p h7z w < F d tzi ?O H9 d dz v y ( d m r z z m 3 ? m [^ N W N N O z z t m S 9 v ?. m ?'? ba o s x a - $ ` z -v 5 L? t7 g; - o ? y / l ? N A q m O oo O '? 9 n $ ? ? ? / ? ?G w A A ,D 9 mm O Q ? 31 5' moSpm^ a w m °o S A l DO El $ x?m a m ,, m n °' 9 I ;Q Q a m 'o n =a @?g m . -.- vm^ om .m 'o 5 'Y.m o ? ac g m ? ? 0 2a2 3? m ?° o S? ? ' w'@ ? m m ? ?Sb ® m 0 8 m nS; °?? S 0 3 $ S - nn 09 9oj o ? m$> °3 x ? $SS . & I flfl _ ?yq? Rq 41 mr$ g 1 U umr KIRK ,'z°.3 n x z 0 yc l x O n n a %? ? ._O ? ?; ?-? ? ? -. -?- - ? ', -,-?, ? ? ? ? ?. .: ?,: ?. M ? ?,. ?< n THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 06-908 - CIVIL TERM Plaintiff, VS. RODNEY STROUP a/k/a RODNEY E. STROUP, Defendant. NOTICE OF ORDER. DECREE OR JUDGMENT TO: RODNEY STROUP a/k/a RODNEY E. STROUP 64 PEACHY ANN DRIVE NEWVILLE, PA 17241 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on () A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $11,705.55 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. RODNEY STROUP a/k/a RODNEY E. STROUP, 64 PEACHY ANN DRIVE NEWVILLE, PA 17241 and MID PENN BANK TO: MID PENN BANK Defendant, Garnishee. 4622 CARLISLE PIKE MECHANICSBURG, PA 17050 CIVIL DIVISION No. 06-908-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. Answers -l-v 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: Checking account number 882829 in the name of Rodney Stroup having a balance as of 5-5-06 of $585.01. 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: see answer number 1 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: see answer number 1 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: see answer number 1 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. see answer number 1 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: see answer number 1 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: see answer number 1 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: see answer number 1 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: see answer number 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). see answer number 1 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: see answer number 1 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: see answer number 1 Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. DATE: l? WU?Q By: V Vl/l Cathy Ann hromulak, Esq. Nancy C. Wilkins, Esq. Jessa C. Martin, Esq. Amy L. Sabolchick, 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. q z :E d I - Ow 9001 aAI83HS 3Hl A 331JJ 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN AFFIDAVIT I, Dennis Spotts Operations Officer of Mid Penn Bank, a Pennsylvania banking corporation, being duly sworn according to law, do depose and say that the answeis set forth in the foregoing Interrogatories are true and correct based upon the best of my knowledge, information and belief. MID PENN BANK By: A..S? ate: Operations Offi Sworn and subscribed to before me, " Notary P bliF, J this ?" day of fl J' 2006 Notary Public my commission expires: CONWEALTH OF P NN V Notarial SW ixie L. Ross, Notary Public ersburg Boro, Dauphin Cotfty ommission E xpires May 5, 2607 ember, Pennsylvania Assocsgon of Nole/lee r ? °- -oc' ?. -a ?? '?' ?D ?? ?? ? ? D' G? ? {-') r, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. RODNEY STROUP a/k/a RODNEY E. STROUP, and MID PENN BANK, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION No. 06-908-CIVIL TERM TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: Defendant's Address: 64 PEACHY ANN DRIVE NEWVILLE, PA 17241 Defendant, Garnishee. Garnishee's Address: 4622 CARLISLE PIKE MECHANICSBURG, PA 17050 Date: April 11, 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 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 4s' Floor Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. RODNEY STROUP a/k/a RODNEY E. STROUP, Defendant, and MID PENN BANK, Garnishee. CIVIL DIVISION No. 06-908-CIVIL, TERM 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 RODNEY STROUP a/k/a RODNEY E. STROUP, defendant, and 3. against MID PENN BANK, garnishee, 4. and index this writ a. against RODNEY STROUP a/k/a RODNEY E. STROUP, defendant, and b. against MID PENN 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. $11,705.55 $ 23.40 $11,728.95 CATHY ANN CHROMULAK, ESQ NANCY C. WILKINS, ESQ. JESSA C. MARTIN, ESQ. AMY L. SABOLCHICK, ESQ. i r c ?t C F?J ? (R ?D V t` v C _ ? N c:. r ^li tt a, ? , W WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-908 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff (s) From RODNEY STROUP A/K/A RODNEY E. STROUP, 64 PEACHY ANN DRIVE, NEWVILLE, PA 17241 (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 MID PENN BANK, 4622 CARLISLE PIKE, MECHANICSBURG, PA 17050 - 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 $11,705.55 Interest $23.40 Arty's Comm % Arty Paid $110.89 Plaintiff Paid Date: APRIL 13, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs 21AS . LO G 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 SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00908 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS STROUP RODNEY AKA RODNEY E STR And now KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:19 Hours, on the 3rd day of May , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT STROUP RODNEY AKA RODNEY E STROUP hands, possession, or control of the within named Garnishee MID PENN BANK 4622 CARLISLE PIKE CSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to in the JOY RATTANA VONG (TELLER) , 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 .00 .00 So answer?t001, R. Thomas Kline Sheriff of Cumberland County 05/04/2006 Sworn and subscribed to before me By this, ( day of eputy iff Pro IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. RODNEY STROUP a/k/a RODNEY E. STROUP, Defendant, and CIVIL DIVISION No. 06-908-CIVIL TERM TYPE OF PLEADING: Praecipe to Discontinue Against Garnishee ONLY TYPE OF CASE: Civil Action MID PENN BANK, Garnishee. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 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 e 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. RODNEY STROUP alkla RODNEY E. STROUP, Defendant, and MID PENN BANK, Garnishee. CIVIL DIVISION No. 06-908-CIVIL TERM PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please discontinue this action against the above garnishee, MID PENN BANK and mark the docket accordingly, Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C By: Y CATHY A6N CHR ULAK, ESQUIRE NANCY C. WILKINS, ESQUIRE JESSA C. MARTIN, ESQUIRE AMY L. SABOLCHICK, ESQUIRE Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscribed me this ?_day oe i/1 1 0 .2006. LV IA THIS IS AN ATTEMPT TO f COLLECT A DEBT AND ANY kWLWabro Pd INFORMATION OBTAINED WILL !dT"-,, Weeliap gtft 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 to Discontinue Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 14th day of June, 2006. MID PENN BANK DENNIS SPOTTS 4622 CARLISLE PIKE MECHANICSBURG, PA 17050 RODNEY STROUP a/k/a RODNEY E. STROUP 64 PEACHY ANN DRIVE NEWVILLE, PA 17241 &IA4 Cathy Chromulak, Esq. Nancy . 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. NJ J C [_ -It tll-r. O It i? V O _ vZ c, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-908 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 RODNEY STROUP A/K/A RODNEY E. STROUP, 64 PEACHY ANN DRIVE, NEWVILLE, PA 17241 (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 MID PENN BANK, 4622 CARLISLE PIKE, MECHANICSBURG, PA 17050 - 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 $11,705.55 Interest $23.40 L.L. $.50 Atty's Comm % Atty Paid $110.89 Plaintiff Paid Date: APRIL 13, 2006 (Seal) Due Prothy $1.00 Other Costs CURT 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 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: Advance Costs: 150.00 Sheriff's Costs 93.54 Docketing 18.00 56.46 Poundage 1.84 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 04/27/07 Mileage 13.20 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 93.54 ? 5?1 ??07 So Answers; a R. Thomas Kline Sheriff s1cr t-,J?a ??,? By(?ka 14 j A" sz ?E U. I d ! - A bbd 9001 J J 5 7, 1! 1l?3