Loading...
HomeMy WebLinkAbout06-5811 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Vs. Plaintiff, CIVIL DIVISION DOUGLASDOTY Defendant(s) No.~-~~~ 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 PAFER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 OR 800-990-9108 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. Plaintiff, vs. DOUGLAS DOTY, Defendant. Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 62 COURTYARD DRIVE CARLISLE, PA 17013 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. TYPE OF PLEADING: Complaint TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID N0.42067 AMY L. SABOLCHICK, ESQ. PA ID N0.94653 ANNA M. BONARRIGO, ESQ. PA ID NO. 202070 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, ~j No. ~t. -- .~~~/ l,. l u i ~ ~L..1~ Plaintiff, 4 1, vs. DOUGLAS DOTY, 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. DOUGLAS DOTY is an adult individual residing at 62 COURTYARD DRIVE, CARLISLE, PA 17013. 3. On or about DECEMBER 19, 2005, 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 AUGUST 17, 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 THIRTEEN THOUSAND SEVEN HUNDRED EIGHTY FIVE AND 53/100 ($13,785.53) DOLLARS as of AUGUST 25, 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 THIRTEEN THOUSAND SEVEN HUNDRED EIGHTY FIVE AND 53/100 ($13,785.53) DOLLARS, with interest thereon at the rate of 24% from AUGUST 25, 2006, plus court costs and attorney's fees. Respectfully submitted, Chromulak & Assoc'ates, LL ~~~ t CAS' Y ANN C OMULAK, ESQ. PA ID NO. 42067 ' 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`~' 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 (callcd "Wc", "Us", "Our"} $ENEFICIAL CONSUMER DISCOUNT COMPANY 419 VILLAGE DRIVE SUITE 2 CARLISLE PA 17013 BORROWERS (called "You", "Your") DOTY, DOUGLAS SS# 576821630 62 COURTYARD DR CARLISLE PA 77013 AIr0~11A1 Molmar pEp~Mp~ OF AVERAGE DAILY BALANCE PERIODIC BATE ~~ 01 AND OVER 2.000 X e 24.000 X a LOAN NO: 711715-73-512163 72000 72/78/05 INITIAL ANNUAL 6UBSEOUENT ANA FEE 5o.oa ~ 50.00 In this Agreement, "you", "your" and "Borrower" mean the customers} who signs this Agreement. "We", "us", and "our" refer to Lender. This Agreement covers the terms and conditions of your Personal Credit Line Account. We want you to understand how your Personal Credit Line Account works. Read this carefully, ask us any questions, and if you agree to be bound by this Agreement, sign below. If more than one person signs, each will be responsible for repaying all sums advanced under this Agreement. Your Credit Line Account is a revolving line of credit extended to you and secured as described below. You can obtain funds from your Personal Credit Line Account {up to your credit limit) directly from us or by using the special checks we supply to you. You may pay your total unpaid balance at any time or in installments. REQUIRED INSURANCE. You must obtain insurance for term of loan covering security for this loan agreement as indicated by the word "YES" below, naming us ns Loss Payee: Physics! damage insurance on vehicle listed under "Security" above, if "Y" appears under "Insured." You may obtain nay required insuran NOTICE: SEE THE FOLLOWING PAGES FOR ADDITIONAL EXHIBIT FORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. I~~~I~Imlll~®~IIII~~I~~III ~{ ~~ ~IIIIII~I~~II~~O'~UUII PA05636i 03-01-00 ~~n u~ u F NRE kD523EAE4CA97R1A9000PA0563610"+~D ORIGINAL 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 c ec t must a written 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, min>;strat~ve 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 special c ec s 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. 1f 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 o or t e ayment mount (as described below) plus any Administrative Charges and credit insurance charges, rounded to the nearest $1; or (2) the Finance Charges due for the billing cycle plus any Administrative 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 t roug over 1.33% through 1.45°70 over 1.45% through 1.57° over 1.57°70 through 1.70% over 1.70°7n through 1.83% over 1.83°.6 through 1.95% over 1.95% Payment Amount . io o ccount glance 1.55° of Account Balance 1.67% of Account Balance 1.80 of Account Balance 1.93° of Account Balance 2.00 of Account Balance 2.15°6 of Account Balance Finance Charges: This is the interest charged on the balance of your Account during each billing cycle. The Finance arge Is ca 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 mtla nnua 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 tD 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 ate c arge of ]0% of the Minimum Monthly Payment due or $20, whichever is greater (excluding any unpaid late charges and amounts due from prior billing cyc}es). NOTICE: SEE THE FOLLOWING PAGES fOR ADDITIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. 03-O1-OD ~1I1011IG~I~II~IIIUIuIIIIIUI{IIII~IUIIIIIIIIII~IIIIII't~~II~~IIII~II~~~~~~~~~~~~~1~ PA056362 F NRE MD523EAE4CA97RLA9000PA0563620""DOTY " ORIGIIVAt PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page 3 of 4) Other Charges: You agree to pay any amounts actually incurred by Lender for services rendered in connection with the ersona re 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: Yau understand that from time to time we may receive credit information concerning you rom of ers, suc 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 far 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. Boa 1547, Chesapeake, VA 2332U. If you fail to fulfill the terms of your credit obligation, a negative report reflecting on your credit record may be submitted to a Credit Reporting Agency. You agree that the Department of Motor Vehicles (or your state's equivalent of such department) may release your residence address to us, should it become necessary to locate you. You agree that our supervisory personnel may listen to telephone calls between you and our representatives in order to evaluate the quality of our service to you. Termination and Changes in the Agreement: We can terminate your right to obtain additional advances or c ange a terms o t ><s greement, inc u ing 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 taw. Default and Cancellation of Agreement: We have the right to require you to pay your entire balance plus all other accru ut unpatl c arges Imme late 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; (~} failure to supply us with any information requested; (d) supplying us with misleading, false, incomplete or incorrect information; (e) breaking any of the promises, terms or conditions that are contained in this Agreement; (f) the filing of a bankruptcy petition by or against you; (g) the death of any borrower who signs this Agreement; or (h) the sale or transfer of any interest in the property securing this agreement (this includes the creation of a subordinate lien}. After default, you will pay our court costs, reasonable attorney fees (if attorney is not our salaried employee), and other collection costs related to the default, if not prohibited by applicable law. Any balance outstanding under this Agreement when the credit limit is terminated will continue to accrue interest at the contract rate until paid in full. YOUR BILLING RIGHTS KEEP THIS NOTICE FOR FUTURE USE This notice contains important imformation about your rights and Lender 's responsibilities under the Fair Credit Billing Act. Notify Lendcr 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 ADDRIONAL PROVISIONS AND IMPORTANT INFORMATION REGARDING YOUR RIGHTS TO DISPUTE BILLING ERRORS. 03-01-OD PA056363 F NRE I~I~i~11IIIUIIII~i~IIIlI1l~~IIIIII~iIII~IVI~I~IIIIi~II~IIIUiI~III~III~QIIgII~~~II~IIIIII~IIIiI~~ ~'D523EAE4CA9TRlA9000PA0563630'~'~DOTY " ORIGINAL 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 there 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 $SO 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 t is oan transaction are incorporat into this Agreement by reference. Applicable Law: The terms and conditions of this Agreement will be governed by the provisions of the Pennsylvania onsumer iscount Company Act, Chapter 7, Sections 6201 through 6221, Purdon's Pennsylvania Statutes Annotated, particularly Section b217.1. Bcfore signing this Agreement, you have read and received this Agreement and the Fedcral 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) usto ignature r ~~ (~ ~ O G) DQ ~I'"_ Date 41 ~ ~--, r-, 1~,11~ a,04~ (SEAL) ustomer ignature Date: Witness: /~_ (SEAL) 03-01-00 RL F NRE II~~~~1~~I~BG~ap~11711~~lllllql~~~I~Il~gllllllalllllllllllll~l~l~l~il~ "D523EAE4CA9)RLA9DOOPA0563640"'~DOTY w ORIGIW-L (SEAL) PA056364 {Page f of 1) LOAN CLOSING STATEMENT REVOLVING LOAN VOUCHER CREDITOR BENEFICIAL CONSUMER DISCOUNT COMPANY 419 VILLAGE DRIVE SUITE 2 CARLISLE PA 17013 BORROWERS DOTY, DOUGLAS 62 COURTYARD DR CARLISLE PA 11013 LOAN NO: 71 1715-13-512163 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.) T0: BENEFICIAL ACCOUNT # 71171506511511 .....................................5 8931.86 Initial Annual Fee ............................................................S 50.00 CASH OR CHECK TO BORROWER .....................................................5 3518.14 TOTAL ADVANCE(S) ..............................................................5 10500.00 B ROWERS: 08- 26-04 I UI~ ~ ~ 9[q~Il) UI~ ~ ~ ~ ~ ~IIIUI llll~ UI~ II ~IIIII ~~ ~lu VIII ~I~~I IIU IIII UII~ ~ ~~ ~ ~~~II ~ IIII RL Voucher PA137921 "p523EAE4CA97RLY9000PAi37921G""DOTY " ORIGINAL VERIFICATION Carrie A. Radcliff ,Recover Specialist for BENEFICIAL CONSUMER DISCOUNT CO?vIPANY 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 coixect to the best of her lmowledge, information and belief. ~~~ Carrie A. Radcliff 1.~ c-~ ~, ~' ~ 'n ~ c-~ ~^ v ` ~~ IV 1 ~ _ i V" tl - . ,T ~o -- cn c:~~ -~-- -- -n ~~ ::~ ~:~ -, ,;~~ ~~ ~_ ~~ ..~ J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 06-5811 CIVIL TERM Plaintiff, TYPE OF PLEADING: vs. Praecipe for Default Judgment DOUGLAS DOTY, TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 62 COURTYARD DRIVE CARLISLE, PA 17013 Defendant. Dated: NOVEMBER 21, 2006 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQUIRE PA ID N0.42067 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 TO: PROTHONOTARY Please enter judgment by default against the within-named defendant, DOUGLAS DOTY, for failure to file an Answer as follows: Amount Claimed in Complaint: $13,785.53 Interest from 8/26/06 through 11/21/06: 702.59 Costs of Collection through 11/21/06: 496.90 TOTAL $14,985.02 With interest accruing on the total balance of $14,985.02 at the rate of 6% per annum, together with additional costs of suit. i BY CATHY CHR MULAK, ESQUIRE AMY L. ABOLCHICK, ESQUIRE ANNA M. BONARRIGO, ESQUIRE Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATION OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF WASHINGTON Before me, the and signed autho~3ty/ a of Public in and for said County and State, personally appeared, ~• C~~b ' ,ESQUIRE, attorney for and authorized representative of pl 'tiff 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 NOVEMBER 8, 2006 by certificate of mailing in , accordance with Pa.R.C.P. 237.1, as evidenced by the att ed copy. ~ / F 7 ~ CATHY CHROMULAK, ESQUIIZE AMY L. S OLCHICK, ESQUIlZE ANNA M. BONARRIGO, ESQUIlZE Sworn to and subscribed before me This~7~ day of yV , 2006. ~141~,,, I,-. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Heather L Hatfield, Notary Public Cecil Ttrrp., Washington County MY Corrunisslon F-xpirr3s Jute 29, 2014 Member, Pennsylvania Association of Notaries THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. T !- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, Vs. DOUGLAS DOTY, Defendant(s). TO: DOUGLAS DOTY 62 COURTYARD DRIVE CARLISLE, PA 17013 DATE OF NOTICE: NOVEMBER 8, 2006 CIVIL DIVISION No. 06-5811 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 THI5 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 800-99 -91 b8 , , „i By: THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CATHY ANN CHR~OMULAK, AMY L. SABOLCHICK, ESQ. ANNA M. BONARRIGO, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4~' Floor Canonsburg, PA 15317 W ~ ^" ~ ~ r. ~'' ~ ~ ~ p~nl j ^' ~N '~ O ~ ~y+~y1 CA a. o gc to ~ ~ ~-• ^ °'' r ~.1 `~ ~ ~ 43 ~ C=7 ~ C17 Lt7 ~ CS7 ~ O "'~ (~Jl a' i n. ~ a ~ m° ~~ -a ~~ f ~~ l+N G m ~ ~ _ 7] O C1 Q. a' ~~~~~~ ~..' ~-~~ ~o ~o ~ .~.~ .~~~~ .~ ,~€ _~ ~~ ~ ~~~~ ~ ~~ ~~ ~ ~~~~a 9. ~ ~' ~# ~. ~ ~~ y ~ ~ ~mmp P a ~ P •~~'~ ~: o,,, N ~~, 6D @~~ 3 P ~~ .~~~ ~~ ~o ~ ~ r~ >yr xm 9~wy~ ~ L=7 ~ ~ d 9 2° , `~° lzJ ~ ~ °. w ~ ~ ~ ~ v -~ - 0 o_d ~ ~ ~ ~~,~' c~~ ~ t'` ~ ~ 9 ~ ' 9 ~ ,,d ~ n a ~r ~ ~_ -o ~ 9 ~ a .~ b~ b x r ~ ~ ~, o N v ~~ j N 3 9 ~ O r N ~ ~ F t5 0°3° ~~~~~ N C'r1 ~,. ~ro. ~ ~ ~ 90~ ~ ~ ~ n 7 ¢y' ~' v m " ~s. . a©~ ~~ ~~~' ~ ~~ ~~ ~ ~~~~ ~ a ~~ a ~ ~ ~a~' ~ G;p. C°J ,~,..o ~ d;,,,,nl uHia~a ~ ~,~,~a~ ~°A ~9,, O W +~'® 'Mip„ ~ ~~ pn ~'~~ G ~ } f M ~ 4f ,I`~~~I p~~` ~~}Y, N ~.f:~~ I;.C7 ~ ~,... m .,.~ G':.J I.~ud ~„e9 G:~A G'FG~ I.d~~ ~„~ ...a. G.n~ ,.a~ ~,a r°a~ r~,;l .. ~ ~ ~ '~ r 1 O A~ ~ ~ `~ N rte, ~~ ~J-, -~i t ~~~" f I r ;~i) ~~ -+! -4 ~ .!.^- ~., ~-~~ =-~: ~, BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 06-5811 CNIL TERM Plaintiff, vs. DOUGLAS DOTY, Defendant. NOTICE OF ORDER DECREE OR JUDGMENT TO: DOUGLAS DOTY 62 COURTYARD DRIVE CARLISLE, PA 17013 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on oU ~T~ 4C.~ In . () A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $14,985.02 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 SHERIFF'S RETURN - REGULAR CASE NO: 2006-05811 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS DOTY DOUGLAS SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DOTY DOUGLAS the DEFENDANT at 1948:00 HOURS, on the 18th day of October 2006 at 62 COURTYARD DRIVE CARLISLE, PA 17013 by handing to DOUGLAS DOTY 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: So Answers: Docketing 18.00 ;~ Service 4.40 ~-'" i ~ Affidavit . 00 ~ ~~"~`'~`'F'"~ Surcharge 10.00 R. Thomas Kline nn 32.40,E 10/19/2006 ~~ I ~~ab~~~ CHROMULAK & ASSOC~ ,ES f Sworn and Subscibed to By: `~ before me this day D uty Sheriff of A.D. ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION: DISCOUNT COMPANY, Plaintiff, No. 06-5811 CIVIL TERM vs. DOUGLAS DOTY, TYPE OF PLEADING: Defendant. Praecipe to Satisfy Judgment TYPE OF CASE: Plaintiff s Address: Civil Action 2700 Sanders Road Prospect Heights, IL 60070 FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID N0.42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 BETH ARNOLD HOWELL, ESQ. PA ID N0.203606 CHRISTINE A. SAUNDERS, ESQ. PA ID N0.203373 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4~h Floor Canonsburg, PA 15317 (724) 916-2400 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, vs. DOUGLAS DOTY, Plaintiff, Defendant. CIVIL DIVISION: No. 06-5811 CIVIL TERM PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please satisfy the judgment against DOUGLAS DOTY, at No. 06-5811 CIVIL TERM, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. ~. ~~ ~ ~~ . Ey: CATHY ANN CHR6iVIULAK, ESQ. MAUREEN A. DOWD, ESQ. BETH ARNOLD HOWELL, ESQ. CHRISTINE A. SAUNDERS, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4~' Floor Canonsburg, PA 15317 Sworn to and subscribed Before me this ~~ day of , 2007. ~~ Notary Publ c COMMONWEALTH OF PENNSYLVANIA Notarial Seel Heather L. Hatf+ela. Notary Public Cell Twp. ~Navningion Courriy My Canmission Expires June 29, 2010 AAember, Pennsylvania Associatior 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 BENEFICIAL CONSUMER DISCOUNT COMPANY, hereby certify that a true and correct copy of the foregoing Praecipe to Satisfy Judgment was served upon the following by First Class Mail, postage prepaid on this 17th day of May, 2007. SHARON DEVOS FREY & TILEY 5 SOUTH HANOVER STREET CARLISLE, PA 17013 ~.~1'l~~i~ a ~(l~a Cathy Ann Chromulak, Esq. Maureen A. Dowd, Esq. Beth Arnold Howell, Esq. Christine A. Saunders, Esq. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. C. ~. ~ 'Tl _..k ---~ j f `~ - ~ ~ ~.-- l., ti " J "°'3 ~~ f~~, ~ . ~ ..~ 3 ~ - y ~M1 ~ '~