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Home My WebLink About06-1978 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff, Vs. KRISTEN FREEMAN AKA KRISTEN N. FREEMAN Defendant(s) CIVIL DIVISION No. 0L -- 19'7 0! U t'F' y, 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION Plaintiff, VS. TYPE OF PLEADING: KRISTEN FREEMAN AKA KRISTEN N. FREEMAN, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 221 W. LOCUST STREET MECHANICSBURG, PA 17055 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Complaint 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 AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, // Plaintiff, V5. KRISTEN FREEMAN AKA KRISTEN N. FREEMAN, 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. KRISTEN FREEMAN AKA KRISTEN N. FREEMAN is an adult individual residing at 221 W. LOCUST STREET, MECHANICSBURG, PA 17055. 3. On or about AUGUST 10, 2005, Defendant entered into a written Loan Agreement with the Plaintiff, as evidenced by the endorsed check, 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. 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 and owing by the Defendant is in the sum of NINE THOUSAND FOUR HUNDRED FORTY NINE AND 32/100 ($9,449.32) DOLLARS as of FEBRUARY 20, 2006. 7. Numerous demands have been made upon Defendant by Plaintiff, but Defendant has failed or refused to pay. 8. Pursuant to the Loan Agreement, Plaintiff is entitled to recover costs of collection and reasonable attorney's fees. WHEREFORE, Plaintiff claims damages in the sum of NINE THOUSAND FOUR HUNDRED FORTY NINE AND 32/100 ($9,449.32) DOLLARS plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC By: CAT Y 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 AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 Attorneys for Plaintiff 375 Southpointe Boulevard THIS IS AN ATTEMPT TO 4`h Fl COLLECT A DEBT AND ANY oor Canonsburg, PA 15317 INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. O (V N m da f" ?LL ZW?5 ag°y xm?N? m? T. Mum r n h a n x v - c - Cb E N I^ h N p Cyy'? Q? Q ? C^ 7 u= Q- 0 3 r r n O r. n M O .r. C_ Nr z U 4 -o E ?Q(D LL N S N to 75. . QO t9 N r N CLE o>a?`: C T? b E y LL me mL 0 C: ? e c9 V M co N E v R ID 10 0 a t i rn??O?NG _ % O -r-- U ` _0 (DO u) W Lr'?? a1? ? -1 ocN??=N 3 > m , . y? T w J LL W N •N. V V 4% N H7 N 3 L r 0 L C3 V LL =z o C N y r i w Q Z N V z N 0 H Q Y" r Q G. ?4A1 V• 7 V r?/f 3 U = V N S N L ?n m O cc O O O I i i j 1 J ? .a Ul Ir ru m O m m N Q' C'- f1J ? 1 O O O c" ?4 V L_ O ? ao J / I ? ?te4l B,n Bn mem yeu 00M m Ae a and WOOOro of a Renviaory heb, a E W unral sipnave of w,tloM d payee OdY 8 der" viv w pavan whoa nama and aft" c W 9 apm on WnGeq. Len dwok mt 4amlratle. i3 = Signing this check wiB result 81 in a loan that must be repaid 1o with interest and fees. ?Y CA 336 ALT c ?. Y- F`?4 RW 1705,zO '? •?32??<. v .r r•? !•V f`tl K"V an to iz r• co i2n 00 O as r'11 ?] 0. i• J ,.. MO r M1 V W ? I.Yi •1 S t ? ( ? • " i 1l X { ?J ,in 11 • co k-u co 00 i h 0 i ?( LL f 70) O LD N..' C) rj) 0 cu U o h , ru (I 1't! N O r" 7, r LTO@d? OW .? NOO" .-a 000 a IFtI d wt kAjj aft ig ?«. II I0hko?ARm ? DO koff SHARE (sea mcbsed ins ist) ME a S € 6 Bs IF sit BOO 9 d10 $ m9 R ,a u it c Eft Cte »?N s? ? g ?T ,E 3 g g d~543 `$ s ? ?Le Cos. 6.Cw.x a p E4 NA? sear g . - ; i C N a ME PROMISSORY NOTE AND DISCLOSURES CREDITOR (Called "We", "Us", "Our") Household Finance Consumer Discount Company Macarthur Towne Centre 2588 Macafhur Road Whitehall, PA 18052 BORROWER (Called "You", "Your"): Sample A. Sample July 2005 C013PAHFG072 Bangor, PA 18013-2501 • ANNUAL PERCENTAGE RATE • FINANCE CHARGE Amount Financetl TDtaI of Payments I Gate The cost of your credo as a The dollar amount the credit The amount of credit The amount you will have of Lean yearly rate. will cost you. I provided to you or on paid after you have made all your behaH. 1 payments as scheduled. 26.839% ?`'?? a $8.000.35 $14,554.20 e' -e July 11, 200 Your Pavmant schedule will be: Number of Payments Amount of Payments When Payments Are Due: 60 5242-57 Monthly, beginning on the Payment Due Date shown on the first Billing Statement. Palestinian: It you pw off early, you mw he entitled to a refund of pad of the Finmtce Charge. Late Charge: If you don't pay any, papnat to 10 days afar iCe due, gas out also pay 1-1R% pm manor as the ameal wants promise to a $1.0(lminimum charge). See below totally additional intormalon about nonpayment defouh, any rewired mwymenl in full before the scheduled data, and prepayment rdunds ant baronet. e means an estimate PROMISE TO PAY By signing me attached check, you agree to the terms of this Promissory Note and Disclosure and promise to pay us the Total of Payments (the sum of Firance Charge plus the Amount Financed) in monthly payments as staled above. Finance Charge includes a nonrefundable fee of $150.00 and interest which has been calculated in advance at the Contract Fee of 2563111%, Per year on the scbedAsi unpaid balances on the assumptions the payments are made on time. DATE ON WHICH FINANCE CHARGES BEGIN. PAYMENT DATES. This loan will be consummated on me dale you cash the check for the loan Proceeds which you received with his Promissory Note and Disclosures. Finance Charges will begin on the dale the check M cashed. PREPAYMENT. If you fully Pay before the final paymeal due dale, the amount you owe will be reduced by unearned Finance Charges (but not the Service charge) determined by the Rule of ]alma LATE CHARGE. If you don't pay any payment in 10 days after Is due, you will also pay 14/2% per month on the amount overdue (subject to a $1.00 minimum marts). BAD CHECK CHARGE. We will charge you a fee of $20 if any payment check is returned because of insufficient funds or is otherwise dishonored You agree that we may detluel this charge from a monthly Payment. rMLURE TO PAY 11 you don't Pay any payment on time (a) all your payments may become due at once and without notifying you before bringing suil, we may sue for the lotal amount you owe less any meamed Finance Charges you would receive if you fully prepad, and (b) you will also pay our reasonable attorney fees, if the stamey is not our salaried employee, for legal proceedings to collect this loan or realize on security. ALTERNATIVE DISPUTE RESOLUTION. Tones of me Anotretion Provision is provided with this Promissory Note and Disclosure and is incerpohned herein by reference. CREDIT REPORTING AND CUSTOMER INFORMATION PRACTICES. If you taij la iWiia the temp of your credit obligm'mn, a negalrve report reflecting on your credit record may be submitted to a Gredh Reporting Agency. You agree that the Department of Motor Vehicles (or your slate's equivalent of with depanmen0 may release your residence address to as, 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 10 evaluate the quality of our service to you. For more information ue dung our privacy pradixs, pease refer to the enebsad Privacy SlatemeM. ITEMIZATION OF AMOUNT FINANCED. The entire Amount Financed (shown appeal will be given directly to YOU. 212262-PA-471-051204 26639PA(07105)444 PACNLB PA0456.06 VERIFICATION Dawn Richt, Recover Specialist for . HOJSFHO D FINANCE CONSUMER DISCOUNT COMPANY 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 .-o ri r SHERIFF'S RETURN - REGULAR CASE NO: 2006-01978 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS FREEMAN KRISTEN AKA KRISTEN N 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 FREEMAN KRISTEN AKA KRISTEN N FREEMAN the DEFENDANT , at 2037:00 HOURS, on the 12th day of April 2006 at 221 W LOCUST STREET MECHANICSBURG, PA 17055 by handing to KRISTEN FREEMAN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.80 Affidavit .00 Surcharge 10.00 nn J V . V V (> Sworn and Subscribed to efore me this day of A. D. So Answers: R. Thomas Kline 04/13/2006 CHROMULAK & ASSOCIATES By: D u y Sheri Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, CIVIL DIVISION: No. 06-1978-CIVIL TERM vs. KRISTEN FREEMAN A/K/A KRISTEN N. FREEMAN Defendant(s). Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 TYPE OF PLEADING: Praecipe to Discontinue Without Prejudice TYPE OF CASE: Civil Action HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY FILED ON BEHALF OF: COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 BETH ARNOLD HOWELL, ESQ. PA ID NO. 203606 TERESA K. FUCHS, ESQ. PA ID NO.205696 JENNIFER M. PALONIS, ESQ. PA ID NO. 205703 CHROMULAK & ASSOCIATES, L.L.C. 401 Technology Drive, Suite 202 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. KRISTEN FREEMAN A/K/A KRISTEN N. FREEMAN, Defendant(s). CIVIL DIVISION: No. 06-1978-CIVIL TERM PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Please discontinue without prejudice the above-captioned action and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. BY?OVo?_ he'? CATHY ANN CHROMULAK, ESQ. BETH ARNOLD HOWELL, ESQ. TERESA K. FUCHS, ESQ. JENNIFER M. PALONIS, ESQ. Attorneys for Plaintiff 401 Technology Drive, Suite 202 Canonsburg, PA 15317 Sworn to and subscribed Before me this day of 12009. Notary Pu lic COMMONWEALTH OF PENNSYLVANIA ;Notarial Seal HeaMer L. Hatfield, Notary Public Cecil Twp., Washington County my commission Expires June 29, 2010 Member, ?snnsy.02nia ssociation of NotarieL THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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 without Prejudice was served upon the following by First Class Mail, postage prepaid on this 3RD day of SEPTEMBER 2009. KRISTEN FREEMAN A/K/A KRISTEN N. FREEMAN 221 WEST LOCUST STREET MECHANICSBURG, PA 17055 ?X px?? Cathy Ann Chromulak, Esq. Beth Arnold Howell, Esq. Teresa K. Fuchs, Esq. Jennifer M. Palonis, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. RED-OFFICE O" 1}4 P? TMTA4 Y 2069 SEP -8 PSI f2'. 22 CLWSEh b Wl1NrY PENt OLVANIA