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Home My WebLink About06-4719IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. 9 LC-- DAVID K. KEISER 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. Plaintiff, VS. DAVID K. KEISER, Defendant. Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY Defendant's Address: 4823 BRIAN ROAD MECHANICSBURG, PA 17050 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 LORI M. DiRENZO, ESQ. PA ID NO. 201843 AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 ANNA M. BONARRIGO, ESQ. PA ID NO. 202070 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 0 Floor Canonsburg, PA 15317 (724) 916-2400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, ?nJ No. DV-'Y'YI4 l?lotL Plaintiff, vs. DAVID K. KEISER, 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. DAVID K. KEISER is an adult individual residing at 4823 BRIAN ROAD, MECHANICSBURG, PA 17050. 3. On or about APRIL 18, 2003, Defendant entered into a written Loan Agreement with the Plaintiff, a copy of which is attached hereto as "Exhibit A" and incorporated herein. 4. Pursuant to the Loan Agreement with Defendant, Plaintiff advanced funds to the Defendant. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5. Defendant is in default under the terms and conditions of the aforementioned Loan Agreement for failing to make payments when due, with the last payment having been made on or about MARCH 3, 2006. 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 EIGHT THOUSAND EIGHT HUNDRED NINETY SEVEN AND 13/100 ($8,897.13) DOLLARS as of JULY 8, 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 EIGHT THOUSAND EIGHT HUNDRED NINETY SEVEN AND 13/100 ($8,897.13) DOLLARS, with interest thereon at the rate of 24% from JULY 8, 2006, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Associates, LLC By: zz'L1?/ CAT NN CHROMULAK, ESQ. PA ID NO. 42067 LORI M. DiRENZO, ESQ. PA ID NO. 201843 AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 ANNA M. BONARRIGO, ESQ. PA ID NO. 202070 Attorneys for Plaintiff 375 Southpointe Boulevard THIS IS AN ATTEMPT TO 4 h 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 4) LENDER (called "We", "Us", "Our") HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY 5105-H JONESTOWN RD COLONIAL COMMONS HARRISBURG PA 17112 BORROWERS (called "You", 'Your") KEISER, DAVID K SS# 162452139 4623 BRIAN RD MECHANICSBURG PA 17050 LOAN NO: -713304-12-124807 Your Credit Line Account is a revolving line of credit extended to you and secured as described below. You can obtain funds from your Personal Credit Line Account (up to your credit limit) directly from us or by using the special checks we supply to you. You may pay your total unpaid balance at any time or in installments. REQUIRED INSURANCE. You must obtain insurance for term of ban covering security for this loan agreement u indicated by the word "YES" below. naming us as Loss Payew Physical damage insurance on vehicle listed under "Security" above, if "Y" appears under "Insured.' You may obtain any required insurance from anyone you choose. FOLLOWING PAGES FOR ADDITIONAL FORMATION REGARDING YOUR I BILLING 3 J OORROR6. I¦1,5,1®,®14 CAg'gIC1) 1,11,0'1 a6t XK34a55IlF159RLA90a0PA0563610aa A ?I ORIGIML PA655361 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. PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 2 of 4) Available Credit: You may obtain funds directly from us or through your special checks up to your available credit. Each check must wntten for at least $100.00. Your available credit is your credit limit (shown on page one) less the total unpaid balance, including Finance Charges, of your Account. If you make loan payments by check, we will adjust your available credit seven days after we receive your check to allow for check clearing. 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) amounts borrowed under this Agreement; (b) Finance Charges, miA? ms arges (the late charge and bad check 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, plus Finance Charges. Payments: You may repay your entire outstanding balance at any time without penalty. You may not use your spacial 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 payment. 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. 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 check charge); Third, to any unpaid credit insurance charges; and Fourth, to the outstanding balance of your Account. Any part 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 part of your 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 (1) the greater of $25 or the Payment mount (as described below) plus any Administrative Charges and credit insurance charges, rounded to the nearest $% or (2) the Finance Charges due for the billing cycle plus any Administrative Charges 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 Payment Amount depends on the monthly periodic rate applicable to your Account, and is calculated as follows Monthly Periodic Rate ffi-rouw =- over 1.33% through 1.45% over 1.45% through 1.57% over 157% through 1.70% over 1.70% through 1.8346 over 1.83% through 1.95% over 1.95% Payment Amount 1.43°? t Balance 1.55% of Account Balance 1.67% of Account Balance 1.80% of Account Balance 1.93% of Account Balance 100% of Account Balance 2.15% of Account Balance Finance Charges: This is the interest charged on the balance of your Account during each billing cycle. The Finance Charge is cu ated from the date that each advance, check 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 rate stated on page one. 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 (but not less than thirty). 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. 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 same 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 agree to 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 atearge 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). NOTICE SEE THE FOLLOWING PAGES FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. 03N-RE-00 PAOSSS62 OK3486511F199RLA9000PA0563620""KEISER 0 ORIGINAL PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 3 of 4) Other Charges: You agree to pay any amounts actually incurred by Lender for services rendered in connection with the Personal It Line Account for fees paid to public officials in connection with perfecting, recording, releasing or satisfying a security interest in the security. You agree that these fees may be charged to your Account balance. Exchange of Information: You understand that from time to time we may receive credit information concerning you from others, such as stores, other lenders, and credit reporting agencies. You authorize us to share any information, on a regular basis, we obtain related to your Account, including but not limited to credit reports and insurance information, with any of our affiliated corporations, subsidiaries or other third parties. The uses of this information may include an inquiry to determine if you qualify for additional offers of credit. You also authorize us to share any information regarding your Account with any of our affiliated corporations, subsidiaries or other third parties. You may prohibit the sharing of such information (except for the sharing of information about transactions or experiences between us and you) by sending a written request which contains your full name, Social Security Number and Address to us at P.O. Box 1547, Chesapeake, VA 23320. If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent of such department) may release your residence address to us, should it become necessary to locate you. You agree that our supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the quality of our service to you. Termination and Changes in the Agreement: We an terminate your right to obtain additional advances or change the terms o is Agreement, Including increasing the rate of Finance Charge at any time. Prior written notice will be given to you when required by applicable law unless you consent to the change before that time. Changes may apply to both new and outstanding balances unless prohibited by applicable law. Default and Cancellation of Agreement: We have the right to require you to pay your entire balance plus all other accrued u unpaid charges Imm ate y an or to cancel your credit privileges under this Agreement because of: (a) failure to make any payments in full when due under this Agreement; (b) frequent overdrawing of your line of credit; (c) failure to supply us with any information requested; (d) supplying us with misleading, false, incomplete or incorrect information; (e) breaking any of the promises, terms or conditions that are contained in this Agreement; (f) the filing of a bankruptcy petition by or against you; (g) the death of any borrower who signs this Agreement; or (h) the sale or transfer of any interest in the property securing this agreement (this includes the creation of a subordinate lien). After default, you will pay our court costs, reasonable attorney fees (if attorney is not our salaried employee), and other collection costs related to the default, if not prohibited by applicable law. Any balance outstanding under this Agreement when the credit limit is terminated will continue to accrue interest at the contract rate until paid in full. YOUR BILLING RIGHTS KEEP THIS NOTICE FOR FUTURE USE This notice contains important information about your rights and Lender's responsibilities under the Fair Credit Billing Act. Notify Lender In Case of Errors or Questions About Your Bill If you think your bill is wrong, or if you need more information about a transaction on your bill, write Lender on a separate sheet at the address listed on your bill after the words: "Send your billing error notice to: (Lender's, name and address)." Write to Lender as soon as possible. Lender must hear from you no later than 60 days after Lender sent you the first bill on which the error or problem appeared. You can telephone Lender, but doing so will not preserve your rights. NOTICE SEE THE FOLLOWING PAGE FOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BIWNG ERRORS. F3WE-00 1011 111101111 PA056363 •K3496511F199RLA9000PA0563630K"KEISER • ORIOIML PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 4 of 4) In your letter, give Lender the following information: • Your name and account number. • The dollar amount of the suspected error. • Describe the error and explain, if you can, why you believe them is an error. If you need more information, describe the item you are not sure about. Your Rights and Lender's Responsibilities After Lender Receives Your Written Notice Lender must acknowledge your letter within 30 days, unless Lender has corrected the error by then. Within 90 days, Lender must either correct the error or explain why Lender believes the bill was correct. After Lender receives your letter, Lender cannot try to collect any amount you question, or report you as delinquent. Lender 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 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 Lender made a mistake on your bill, you will not 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 Lender that you still refuse to pay, Lender must tell anyone Lender reports you to that you have a question about your bill. And, Lender 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 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 Riders: The terms of the Arbitration Agreement and any other Riders sign as part o this loan transaction are mcorpora Into this Agreement by reference. Applicable Law: The terms and conditions of this Agreement will be governed by the provisions of the Pennsylvania Consumer scount Company Act, Chapter 7, Sections 6201 through 6221, Putdon's Pennsylvania Statutes Annotated, particularly Section 6217.1. 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. This Agreement is entered under the applicable provisions of Federal law and the Pennsylvania Consumer Discount Company Act. (SEAL) Customer Signature (SEAL) Customer Signature Date: y -,/ F-42 3 Wi (SEAL) 03-01-00 RL F NRtE Data PA0SS394 ¦K34Ga511FIOSALA9000PA0563040NWEISER • ORIGINAL LOAN CLOSING STATEMENT REVOLVING LOAN VOUCHER CREDITOR HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY 5105-H JONESTOWN RD COLONIAL COMMONS HARRISBURG PA 11112 BORROWERS KEISER, DAVID K 4823 BRIAN RD MECHANICSBURG PA 11050 LOAN NO: 713304-12-124807 Borrowers agree to and direct the disbursements and Advance indicated below. If any estimated amount shown below varies from the actual amount paid, Borrowers agree to the disbursement of the actual amount and a corresponding change to the Advance shown below. Borrowers agree that this Advance is made under Borrowers' Revolving Loan Agreement (account number shown above.) INITIAL ANNUAL FEE ............................................................5 50.00 CASH OR CHECK TO BORROWER .....................................................a 8850.00 TOTAL ADVANCE(S) ..............................................................9 10000.00 BORROWERS: rpm/ "Zz4a-? 09-20-99 RL Voucher •K34OSS11F199RLV9000PA1379110-NKEISER • ORIGINAL PA137911 DATE VERIFICATION Carrie A. Radcliff Recover Specialist for HOUSEHOLD 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. I n t-)7x - ?J rrie A. Rad 1 ff i 7 IAJ n p Pn c_ „ Alp -v C .r- C] CJ SHERIFF'S RETURN - REGULAR CASE NO: 2006-04719 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS KEISER DAVID K TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon KEISER DAVID K the DEFENDANT , at 0011:02 HOURS, on the 8th day of September, 2006 at 4823 BRIAN ROAD MECHANICSBURG, PA 17050 by handing to JOSEPH MORRIS {ADULT IN CHARGE a true and attested copy of NOTICE COMPLAINT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 9.68 ?000 . Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 37.68,,/ 09/11/2006 CHROLULAK & ASSOC Sworn and Subscibed to By: -------- before me this day De ty Sheri of A.D. r ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 06-4719 - CIVIL TERM Plaintiff, TYPE OF PLEADING: vs. Praecipe for Default Judgment DAVID K. KEISER, Defendant. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 4823 BRIAN ROAD MECHANICSBURG, PA 17050 TYPE OF CASE: Civil Action FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQUIRE PA ID NO. 42067 AMY L. SABOLCHICK, ESQUIRE PA ID NO. 94653 ANNA M. BONARRIGO, ESQUIRE PA ID NO. 202070 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 Dated: OCTOBER 10, 2006 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r .. TO:PROTHONOTARY Please enter judgment by default against the within-named defendant, DAVID K. KEISER, for failure to file an Answer as follows: Amount Claimed in Complaint: Interest from 7/09/06 through 10/10/06: 515.88 Costs of Collection through 10/10/06: 502.18 TOTAL $9,915.19 With interest accruing on the total balance of $9,915.19 at the rate of 6% per annum, together with additional costs of suit. /-? BY 1 CATHY AMY L. SABOLCHICK, ES( ANNA M. BONARRIGO, ES Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATION OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT SS: COMMONWEALTH OF PENNSYLVANIA $8,897.13 COUNTY OF WASHINGTON Before me, the undersigned authority, a Notary Public in and for said County and State, personally appeared, /?NN;? " 2G? (5) Q , 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 SEPTEMBER 29, 2006 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the att ed copy. QUIRE C THY ANN CHROMULAK, EAi AMY L. SABOLCHICK, ESQU ANNA M. BONARRIGO, ESQUIRE Sworn to and subscribed fore me This_ day of , 2006. THIS IS AN ATTEMPT TO OBTAINED WILL BE USED FOR THAT PURPOSE. 1 Not blic COMMONS _ k ?' C PENNSYLVANIA .OTafy Public Nlrc _'?,?r noon County 3 y Pviember. Pennsylvania Association Of Notaries COLLECT A DEBT AND ANY INFORMATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, Vs. DAVID K. KEISER, Defendant(s). TO: DAVID K. KEISER 4823 BRIAN ROAD MECHANICSBURG, PA 17050 DATE OF NOTICE: SEPTEMBER 29, 2006 CIVIL DIVISION No. 06-4719 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 By: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CATHY ANN CHROMU AMY L. SABOLCHIC E ANNA M. BONARRIG , Attorneys for Plaintiff 375 Southpointe Boulevard 4`h Floor Canonsburg, PA 15317 T 0 3 0 s I 6 = g3 m Y? m° w 7111 c n3 a? N .P W LO OD J to , w ? CA ?d >m ?'x wZbdEn om 7z Zo `n m a4 o-? , rn r l , V am N r 7,? 91 U ? ~ m r A [Q1 m 3 m a -4 r a Igo 0 9 r? ? 1 o o o 'd r O a O kv 0 °0= 0W? ° nm o_ 3 ao a?. v m?o o x ?z a to9ma m ?` o ? m m m m s Oa ? sVC m 40 'O T m ?-°o m UNMEOIV) {S ltt G;:.1`? 409. \? 41 r C.? 3 r, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 06-4719 - CIVIL TERM Plaintiff, VS. DAVID K. KEISER, Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: DAVID K. KEISER 4823 BRIAN ROAD MECHANICSBURG, PA 17050 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on Q (PT.26ob _ () A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $9,915.19 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. DAVID K. KEISER, and WACHOVIA BANK, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant, Garnishee. Defendant's Address: 4823 BRIAN ROAD MECHANICSBURG, PA 17050 Garnishee's Address: 604 EAST HIGH STREET CARLISLE, PA 17013 Date: October 30, 2006 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 06-4719-CIVIL TERM TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 ANNA M. BONARRIGO, ESQ. PA ID NO. 202070 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 Tr.? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. DAVID K. KEISER, and WACHOVIA BANK, TO: The Prothonotary Defendant, Garnishee. CIVIL DIVISION No. 06-4719-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION Please issue a Writ of Execution in the above matter, 1. directed to the Sheriff of CUMBERLAND County; 2. against DAVID K. KEISER, defendant, and 3. against WACHOVIA BANK, garnishee, 4. and index this writ a. against DAVID K. KEISER, defendant, and b. against WACHOVIA BANK, garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendant in any accounts individual and joint, personal and business. 5. Amount of Judgment Additional Interest to Date (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. $9,915.19 $ 23.10 $9,938.29 CATHY CHROMULAK, ESQ. AMY L. ABOLCHICK, ESQ. ANNA M. BONARRIGO, ESQ. vi ? Ra ?tJ U't ;r2 r s i `W? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4719 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 DAVID K. KEISER, 4823 BRIAN ROAD, MECHANICSBURG, PA 17050 (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 WACHOVIA BANK, 604 EAST HIGH STREET, CARLISLE, PA 17013 - ALL MONIES DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $9,915.19 Interest TO DATE - $23.10 Atty's Comm % Atty Paid $119.68 Plaintiff Paid Date: NOVEMBER 2, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs Curtis A. Long, Pr nota By: Deputy REQUESTING PARTY: Name AMY L. SABOLCHICK, 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. 94653 SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. DAVID K. KEISER and NO. 06-4719-CIVIL WACHOVIA BANK, N.A., GARNISHEE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Wachovia Bank, N.A., Garnishee, in the above-captioned matter. Date: ? ? ? ? ? ? ? , y N ? .. ... .` _ ?,,. ?' f ? # `?r-; °' ? fr.. ?.? Y + ? _-?? ??? ?? Wt c f,% SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS COUNTY OF CUMBERLAND VS. DAVID K. KEISER and WACHOVIA BANK, N.A., CTARNISHRR NO. 06-4719-CIVIL TO: HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff 1. No. 2. Account titled David K. Keiser with a balance of $2,516.65, and an account titled David K. Keiser with a zero balance. The total sum of $2,516.65 has been restricted pursuant to this Writ. Pursuant to the terms and conditions of the deposit agreement between the bank and the depositor, the bank claims a priority lien in, and a right of set-off against the account consisting of $100.00 Legal Processing Charge, leaving a balance for execution purposes of $2,416.65. In addition, pursuant to 42 Pa.C.S.A. Section 2503, garnishee attorneys fees are authorized in an amount to be determined and deducted from the attached funds. 3. - 6. No. 7. See answer to number two above. JON C. $ WIN Attorne or Garnishee Dated: I / w R'achovia Bank. N.A. P.O. Box 8667, Philadelphia. Pennsylvania 19101-8667, V ? 1.ti Verification . Kathleen Gormley, being duly sworn according to law, deposes and says that she is the Writ of Execution Administrator of Wachovia Bank, N.A. Garnishee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to sworn falsification to authorities. Kathleen Gormley Manager Dated: r? 3 0 '? 4 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, VS. DAVID K. KEISER, and WACHOVIA BANK, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant, Garnishee. CIVIL DIVISION No. 06-4719-CIVIL TERM TYPE OF PLEADING: Praecipe to Discontinue Against Garnishee ONLY 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 AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 ANNA M. BONARRIGO, ESQ. PA ID NO. 202070 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4"' 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 HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY, Plaintiff, vs. DAVID K. KEISER, and WACHOVIA BANK, Defendant, Garnishee. CIVIL DIVISION No. 06-4719-CIVIL TERM PRAECIPE TO DISCONTINUE AGAINST GARNISHEE ONLY TO PROTHONOTARY: Please discontinue this action against the above garnishee, WACHOVIA BANK, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. i By: CATHY RO ULAK, ESQUIRE AMY L. S OLCHICK, ESQUIRE ANNA M. BONARRIGO, ESQUIRE Attorneys for Plaintiff 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 Sworn to and subscribed Before me this Ilk- day of_,` ,, 2006. 4ofvw ?.? Notary Pub is COMM NWEALTH OF PENNSYLVANIA Notarial Seal Heather L Hatfield, Notary Public Cecil Twp., Washington County My Commission Expires June 29, 2010 Member, Pennsylvania Association of Notaries 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 Against Garnishee Only was served upon the following by First Class Mail, postage prepaid on this 12th day of December, 2006. JON C. SIRLIN SIRLIN, GALLOGLY & LESSER 1529 WALNUT STREET SUITE 600 PHILADELPHIA, PA 19102 DAVID K. KEISER 4823 BRIAN ROAD MECHANICSBURG, PA 17050 LEE ERIC OESTERLING 42 EAST MAIN STREET MECHANICSBURG, PA 17055 l? Cathy Chromulak, Esq. Amy L. abolchick, Esq. Anna M. Bonarrigo, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. trod °= C:D CiN SIRLIN GALLOGLY & LESSER, P.C By: Jon C. Sirlin, Esquire, I.D. No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee HOUSEHOLD FINANCE CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. DAVID K. KEISER and NO. 06-4719-CIVIL WACHOVIA BANK, N.A., CTARNIS14RE ATTORNEY I.D.#17498 Garnishee, Wachovia Bank, N.A., hereby bills the following costs to the fund attached and will be satisfied therefrom, as authorized by 42 Pa.C.S.A. Section 2503: Garnishee's fee pursuant to 42 Pa. C.S.A Section 2503: Notary Charges: Entry of Appearance: Answers to Interrogatories: Order to Discontinue or Satisfy: Other: TOT JON C. ? Attorney Costs are hereby taxed in the amount of _????y of 2006. BY: jFAM 4..t SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-04719 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND HOUSEHOLD FINANCE CONSUMER VS KEISER DAVID K And now DAVID MCKINNEY ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:33 Hours, on the 15th day of November , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , KEISER DAVID K _ in the hands, possession, or control of the within named Garnishee WACHOVIA LANK 604 E. HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to PAUL STOW (TELLER) personally three copies of interogatorles together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to His . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 -1/ .00 Sworn and Subscribed to before me this day of true and made So answers: R. Thomas Kline Sheriff of Cumberland County 11/17/2006 By Deputy Sheriff A.D 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: Docketing 18.00 Poundage 1.66 Advertising Law Library .50 Prothonotary 1.00 Mileage 4.40 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 TOTAL 84.56 J R.?I'homas ine, Sheri By _0? 0 t 1-4 -4 ® SS :8 V L- AON 9001 JJI{ 3HS" 311I) Advance Costs: 150.00 Sheriff's Costs 84.56 65.44 Refunded to Atty on 09/ 11 /07 yy Q/zy/ 07 So Answers, ?e 1,,P oo? 4 P3',) 7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-4719 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 DAVID K. KEISER, 4823 H11JAN ROAD, MECHANICSBURG, PA 17050 (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 WACHOVIA BANK, 604 EAST HIGH STREET, CARLISLE, PA 17013 - ALL MONIES DUE DEFENDANT IN ANY ACCOUNTS, INDIVIDUAL AND JOINT, PERSONAL AND BUSINESS GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) this garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defaidant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $9,915.19 Interest TO DATE - $23.10 Atty's Comm % Atty Paid $119.68 Plaintiff Paid Date: NOVEMBER 2, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs Curtis X. Long, Pr otmf By: Deputy REQUESTING PARTY: Name AMY L. SABOLCIUCK, ESQUIRE Address: CH ROMULAK & ASSOCIATES, L.L.C. 375 SOUTHPOINTE BOULEVARD 4TH FLOOR CANONSBURG, PA 15317 Attorney for: PLAINTIFF Telephone: 724-916-2400 Supreme Court ID No. 94653