Loading...
HomeMy WebLinkAbout06-6843IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY Plaintiff, CIVIL DIVISION Vs. No. O RAYMOND R. STRAIT and CYNTHIA K. STRAIT 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 BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. O(, - G F y43 Plaintiff, vs. TYPE OF PLEADING: Complaint RAYMOND R. STRAIT and TYPE OF CASE: CYNTHIA K. STRAIT Defendants. Civil Action FILED ON BEHALF OF: Plaintiff s Address: BENEFICIAL CONSUMER 2700 Sanders Road DISCOUNT COMPANY Prospect Heights, IL 60070 COUNSEL OF RECORD: Defendants' Address: CATHY ANN CHROMULAK, ESQ. 174 RUSTIC DRIVE PA ID NO. 42067 SHIPPENSBURG, PA 17257 AMY L. SABOLCHICK, ESQ. PA ID NO. 94653 ANNA M. BONARRIGO, ESQ. PA ID NO. 202070 CHROMULAK & ASSOCIATES, LLC 375 Southpointe Boulevard 41h 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 CIVIL DIVISION DISCOUNT COMPANY, No. bG , 4,jpy3 C?Lj T-- Plaintiff, vs. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, Defendants. 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. RAYMOND R. STRAIT and CYNTHIA K. STRAIT are adult individuals residing at 174 RUSTIC DRIVE, SHIPPENSBURG, PA 17257. 3. On or about OCTOBER 27, 2004, Defendants 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 the Defendants, Plaintiff advanced funds to the Defendants. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 5. Defendants are 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 31, 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 Defendants is in the sum of TEN THOUSAND SEVEN HUNDRED FIFTY THREE AND 69/100 ($10,753.69) DOLLARS as of OCTOBER 17, 2006. 7. Numerous demands have been made upon the Defendants by Plaintiff, but the Defendants have 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 TEN THOUSAND SEVEN HUNDRED FIFTY THREE AND 69/100 ($10,753.69) DOLLARS, with interest thereon at the rate of 24% from OCTOBER 17, 2006, plus court costs and attorney's fees. Respectfully submitted, By: AMY L. SABOLCHICK, ESO' PA ID NO. 94653 ANNA M. BONARRIGO, ESQ. PA ID NO. 202070 Attorneys for Plaintiff 375 Southpointe Boulevard 4`h Floor THIS IS AN ATTEMPT TO Canonsburg, PA 15317 COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Chromulak & Associates, LLC PERSONAL CREDIT LINE ACCOUNT AGREEMENT (Page I of 4) LENDER (called "We", BENEFICIAL CONSUMER 983 WAYNE AVENUE "Us", "Our") DISCOUNT COMPANY CHAMBERSBURG PA 17201 BORROWERS (called "You", "Your") STRAIT, RAYMOND R SS# 176561195 STRAIT, CYNTHIA K SS# 207463852 172 RUSTIC DR SHIPPENSBURG PA 17257 01 AND OVER 2.000 % a 24.000 % a s LOAN NO: 711716-16-507748 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. 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 as Loss Payee: ' Physical damage insurance on vehicle listed under "Security" above, if "Y" appears under "Insured." You may obtain any required ' Dose. NOTICE SEE THE FOLLOWING PAGES FOR ADDI EXHIBIT AMi INFORMATION REGARDING YOUR RIGHTS TO DISPUTE 03-01-00 L RRORS. IIII?I?? ? ?` ?j Na? l? 111161 PA056361 F NRE "178009599889RLA8000PAO5 8 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 check must 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, ministratlive 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' foes; 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 iecEtt 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 t e Payment mount (as described below) plus any Administrative Charges and credit insurance charges, rounded to the nearest $l; 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 through over 1.33% through 1.45% over 1.45% through 1.57% over 1.57% through 1.70% over 1.70% through 1.83% over 1.83% through 1.95% over 1.95% Payment Amount I A3% o ccount alance 1.55% of Account Balance 1.67% of Account Balance 1.80% of Account Balance 1.93% of Account Balance 2.00°x6 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 ca cuTated 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 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 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 ate c arge 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. F NRE 03-01-00 11101111101111M N 111110®M®1Ia1 111 PA056362 F NRE M178009599889RLA8000PA0563620M"STRAIT M 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 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: You understand that from time to time we may receive credit information concerning you rom 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 can terminate your right to obtain additional advances or change the terms o is Agreement, I,ne u 1ng 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 unpal charges imm Ia 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 imformation 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 BILLING ERRORS. F F NRE NRE 03-01-00 IN 11111? IN onI M1M111N1011§1 11millIII PA056363 K1780095998B9RLASODOPA0563830KKSTRAIT K 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 $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 sigriect as part o this oan 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 jscount Company Act, Chapter 7, Sections 6201 through 6221, Purdon'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. r` /A? (SEAL) r" t ignature Date: _/V/ 2 7 / y V (SEAL) au7ftme ign re Date: f p7 fl O Witness: (SEAL) t?aa,714-AkAdf- (SEAL) RL F }NRE PAOSS364 "178009599889RLA9000PAOS63640N"STRAIT M ORIGINAL LOAN CLOSING STATEMENT (Page I of I) REVOLVING LOAN VOUCHER CREDITOR BENEFICIAL CONSUMER DISCOUNT COMPANY 983 WAYNE AVENUE CHAMBERSBURG PA 17201 BORROWERS STRAIT, RAYMOND R STRAIT, CYNTHIA K 172 RUSTIC OR SHIPPENSBURG PA 17257 LOAN NO: 711716-16'507748 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.) TO: BENEFICIAL ACCOUNT # 71171600558924 .....................................5 5083.28 Initial Annual Fee ............................................................t 50.00 CASH OR CHECK TO BORROWER ....................................... .............. : 3186.72 TOTAL ADVANCE(S) ..............................................................t 9300.00 BORROWERS: os-zs-oa RL Voucher ¦178009599889RLVB000PA1379210""STRAIT " ORIGINAL PA137921 VERIFICATION Carrie A. Radcliff , Recover Specialist for Beneficial 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. Carrie A. Radcliff E i f cat C -r. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 06-6843 Plaintiff, vs. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, TYPE OF PLEADING: Praecipe to Reinstate Complaint TYPE OF CASE: Defendants. Plaintiff s Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendant's Address: 11287 MOUNTAIN ROAD ORRSTOWN, PA 17244 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Civil Action FILED ON BEHALF OF: BENEFICIAL 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 06-6843 Plaintiff, VS. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, Defendants. PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the complaint in the above-captioned action, at 06-6843 and mark the docket accordingly. BY CATHY A CHRO ULAK, ESQ. AMY L. SABOLCHICK, ESQ. ANNA M. BONARRIGO, ESQ. 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. i o Fri r, ry ?( ? t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, Defendants. Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendants' Address: 11287 MOUNTAIN ROAD ORRSTOWN, PA 17244 Dated: FEBRUARY 27, 2007 CIVIL DIVISION No. 06-6843-Civil 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 MAUREEN A. DOWD, ESQUIRE PA ID NO. 90549 KURT J. WINTER, ESQUIRE PAID NO. 84801 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, Pennsylvania 15317 (724) 916-2400 .-'L . b ' TO:PROTHONOTARY Please enter judgment by default against the within-named defendants, RAYMOND R. STRAIT and CYNTHIA K. STRAIT, for failure to file an Answer as follows: $10,753.69 857.60 Costs of Collection through 2/27/07: 663.85 TOTAL $12,275.14 With interest accruing on the total balance of $12,275.14 at the rate of 6% per annum, together with additional costs of suit. Amount Claimed in Complaint: Interest from 10/18/06 through 2/27/07: BY CATHY ANN PIROMULAK, ESQUIRE MAUREEN A. DOWD, ESQUIRE KURT J. WINTER, ESQUIRE Attorneys for Plaintiff 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 undersigned authority, a Notary Public in and for said County and State, personally appeared, T ? y?ri?TFGz , 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/his knowledge, information and belief and certifies that the Notice of Intent to take Default Judgment was mailed to defendants on FEBRUARY 16, 2007 by certificate of mailing in accordance with Pa.R.C.P. 237.1, as evidenced by the attached copy. ...?? CATHY ANN HROMULAK, ESQUIRE MAUREEN A. DOWD, ESQUIRE KURT J. WINTER, ESQUIRE Sworn to and subscribed efore me This day of Uykgm , 2007. 14? ?. Notary Public COMMONWEALTH OF PENNSYLVANItt Notarial Seal Heather L. Hatfield, Notary Public. Cecil Twp., Washington County My Commission Expires June 29, 2010 Member, Pa,-7-vlvs,nira ":=sociPtion of Notarier 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. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, Defendants. TO: RAYMOND R. STRAIT 11287 MOUNTAIN ROAD ORRSTOWN, PA 17244 DATE, OF NOTICE: FEBRUARY 16, 2007 4 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:z ?- CATHY A CHROMULAK, ESQ. MAUREEN A. DOWD, ESQ. KURT J. WINTER, ESQ. THIS IS AN ATTEMPT TO Attorneys for Plaintiff COLLECT A DEBT AND ANY 375 Southpointe Boulevard INFORMATION OBTAINED WILL 4`h Floor BE USED FOR THAT PURPOSE. Canonsburg, PA 15317 CIVIL DIVISION No. 06-6843 1 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, Defendants. TO: CYNTHIA K. STRAIT 11287 MOUNTAIN ROAD ORRSTOWN, PA 17244 I DATE OF NOTICE: FEBRUARY 16, 2007 CIVIL DIVISION No. 06-6843 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 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. By: CATHY ANN CHROMULAK, ESQ. MAUREEN A. DOWD, ESQ. Attorneys for Plaintiff 375 Southpointe Boulevard 4TH Floor Canonsburg, PA 15317 T O ?.1 NT a T\.M m? e? m $ o 0 06' 0 •21 P ? Z w ro ? 9, 1111$ c'N O- o OR C 1 j ar n f m w N ? W cn ? O O ? ?9 O "?'? C7 ? 9 ? x 0 00 N "` W wd rn G] O 'z L!? 1 ?51 O Ox p x9 n? C, ?C '? C? lT1 ? cn t' v r?' w 9?'y??? ?Q ?O a `a ? O ?, 9 b y ? b b a ° ? fl .P N 9 r r - m 0 ?2 m a a r N ? o 3 0 om. m m v `? a o n om o v? ?. ? a m m !B v pa2 s 1'J.4 ? d;mn;l u?r?os? .yt 11„m?? 81?ti u jVw .rte I?mnnt. ?? C? 1°•s't ??,CS t";?;11,.,od L.a,# ? ? ? wiz -? ? -,-1 4 ? ?" t ? ? t;l 'T'^ ?".? ? t ? ? ?_l `-" ??..3 e? ' ? T 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER CIVIL DIVISION DISCOUNT COMPANY, No. 06-6843-Civil Plaintiff, VS. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: RAYMOND R. STRAIT 11287 MOUNTAIN ROAD ORRSTOWN, PA 17244 (X) Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on -?nr? / . 2p d 7 () A copy of the Order or Decree is enclosed, or (X) The judgment is as follows: $12,275.14 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 CIVIL DIVISION DISCOUNT COMPANY, No. 06-6843-Civil Plaintiff, vs. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, Defendants. NOTICE OF ORDER DECREE OR JUDGMENT TO: CYNTHIA K. STRAIT 11287 MOUNTAIN ROAD ORRSTOWN, PA 17244 (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: $12,275.14 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. SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-06843 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS STRAIT RAYMOND R ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT STRAIT RAYMOND R but was unable to locate Him in his bailiwick !1YIMDT.7T TTT'r C'- T nrrTt1 He therefore returns the the within named DEFENDANT STRAIT RAYMOND R 174 RUSTIC DRIVE NOT FOUND , as to SHIPPENSBURG, PA 17257 174 RUSTIC DRIVE IS VACANT. DEFENDANT IS BELIEVED TO BE LIVING IN ORRSTOWN. Sheriff's Costs: So answers: Docketing 18.00 Service 18.48 Not Found 5.00 R. Thomas K e Surcharge 10.00 Sheriff of Cumbe and County .00 51.48/ CHROMULAK & ASSOCIATES g, 12/12/2006 ?l? 307 Sworn and Subscribed to before me this day of , A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-06843 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS STRAIT RAYMOND R ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT STRAIT CYNTHIA K but was unable to locate Her in his bailiwick. He therefore returns the 1Y/ W,TIT T TTTrP C, 7KTnMT(7V the within named DEFENDANT 174 RUSTIC DRIVE SHIPPENSBURG, PA 17257 174 RUSTIC DRIVE IS VACANT. DEFENDANT IS BELIEVED TO BE LIVING IN ORRSTOWN. Sheriff's Costs: So answers Docketing 6.00 Service .00 Not Found 5.00 R. Thomas line Surcharge 10.00 Sheriff of Cumberland County .00 21.00,,- CHROMULAK & ASSOCIATES 12/12/2006 Sworn and Subscribed to before me this day of , A. D. .. m.-.r Tm n<TUTmTrT•T v NOT FOUND , as to t SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-06843 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS STRAIT RAYMOND R ET AL R. Thomas Kline .00 110.8 7 7 i/,z-0/0 -7 L?_ 01/10/2007 CHROMULAK & ASSOCIATES duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT STRAIT RAYMOND R but was unable to locate Him Sheriff or Deputy Sheriff who being to wit: in his bailiwick. He therefore deputized the sheriff of FRANKLIN serve the within COMPLAINT & NOTICE On January 10th , 2007 , attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep Franklin Co Sworn and subscribe to before me this day of , So answe 18.00 9.00 10.00 R. Thomas Kline 73.87 Sheriff of Cumberland County County, Pennsylvania, to s office was in receipt of the A. D. .4 In The Court of Common Pleas of Cumberland County, Pennsylvania Beneficial Consumer Discount Ctmpany vs. Raymond R. Strait et al SERVE: Raymond R. Strait No. 06-6843 civil Now, December 27, 2006 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, 2-1 , 20 , at I6 b o'clock A M. served the within Ea?- 0jC'0 ck'3 rf:j j upon at 1 / 2 P7 ?1o,.sH fir( N PA. 17-),VV by handing to a (a? C z copy of the original and made known to Sworn and subscrib before me this,,.-6r# day o , 20049 Notarial Seal Richard D. McCarty, Notary Public Chambersburg Boro, Franklin County My Commission Expires Jan. 29, 2007 So answers, Cerr.PLA i k.-r the contents thereof. - ?=&,'u i A j- - Sheriff of (T j County, PA COSTS SERVICE _ MILEAGE _ AFFIDAVIT $ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-06843 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS STRAIT RAYMOND R ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: STRAIT CYNTHIA K but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On January 10th , 2007 this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: So answer-S-11 Docketing 6.00 Out of County .00 Surcharge 10.00 Thomas Kline .00 Sheriff of Cumberland County .00 16. 0 0 01/10/2007 CHROMULAK & ASSOCIATES Sworn and subscribe to before me this day of , A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Beneficial Consumer Discount Company vs. Raymond R. Strait et al SERVE: Cynthia K. Strait Now, December 27, 2006 hereby deputize the Sheriff of No. 06-6843 civil I, SHERIFF OF CUMBERLAND COUNTY, PA, do Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, 6? Z2 10n? , 20 , at o05 o'clock Pr- _M. served the within ?2 K? c?v ???' y upon gw-r 4i A 5Ta 4 c at ! IL,?-? M t chi N (ZO - If f)QjZS-Tb U ?' j P A. 172- Y V by handing to a copy of the original Cory\p -A, 0-F and made known to ?(4- the contents thereof. So answers, Sheriff of a- (i - County, PA Sworn andddgubscrib efore me this day of , 20 0 Notarial Seal Richard D. McCarty, Notary Public Chambersburg Boro, Frankiin County My Commission Expires Jan. 29, 2no7 COSTS SERVICE $ MILEAGE AFFIDAVIT $ ?3 s ? asr? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, vs. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, and M&T BANK, Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 Defendants' Address: 11287 MOUNTAIN ROAD ORRSTOWN, PA 17244 Garnishee's Address: 1 WEST HIGH STREET CARLISLE, PA 17013 Date: March 21, 2007 Plaintiff, Defendants, Garnishee. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. CIVIL DIVISION No. 06-6843-CIVIL TYPE OF PLEADING: PRAECIPE FOR A WRIT OF EXECUTION FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY COUNSEL OF RECORD: CATHY ANN CHROMULAK, ESQ. PA ID NO. 42067 MAUREEN A. DOWD, ESQ. PA ID NO. 90549 KURT J. WINTER, ESQ. PA ID NO. 84801 CHROMULAK & ASSOCIATES, L.L.C. 375 Southpointe Boulevard 4th Floor Canonsburg, PA 15317 (724) 916-2400 I-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, CIVIL DIVISION No. 06-6843-CIVIL Plaintiff, VS. RAYMOND R. STRAIT and CYNTHIA K. STRAIT, Defendants, and M&T BANK, Garnishee. 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 RAYMOND R. STRAIT, defendant, and 3. against CYNTHIA K. STRAIT, defendant, and 4. against M&T BANK, garnishee, . 5. and index this writ a. against RAYMOND R. STRAIT, defendant, and b. against CYNTHIA K. STRAIT, defendant, and c. against M&T BANK, garnishee, and any property of the defendant in the name of Garnishee: Said Writ of Execution is pursuant to all monies due defendants in any accounts, individual and joint, personal and business. 6. Amount of Judgment Additional Interest to Date (Costs to be added) $12,275.14 $ 41.00 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. $12,316.14 CATHY A CHROMULAK, ESQ. MAUREEN A. DOWD, ESQ. KURT J. WINTER, ESQ. 40 e1 ? W v i r -70 w ? ? w WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-6843 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 RAYMOND R. STRAIT AND CYNTHIA K. STRAIT, 11287 MOUNTAIN ROAD, ORRSTOWN, PA 17244 (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 M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 - ALL MONIES DUE DEFENDANTS 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 $12, 275.14 Interest $41.00 Atty's Comm % Atty Paid $287.85 Plaintiff Paid Date: MARCH 28, 2007 L.L. $.50 Due Prothy $2.00 Other Costs $50 DUE GARNISHEE Curtis . Lo , ro onot (Seal) By: Deputy REQUESTING PARTY: Name KURT J. WINTER, 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. 84801 SHERIFF'S RETURN - GARNISHEE CASP NO: 2006-06843 P jCOMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS STRAIT RAYMOND R ET AL And now STEVE BENDER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:20 Hours, on the 11th day of April , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , STRAIT RAYMOND R hands, possession, or control of the within named Garnishee M & T BANK 1 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to in the BROOKE GRODIN 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: SDocketing .00 '? Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 0 0 ? '??/41? ?" 04/12/2007 Sworn and Subscribed to before me this day of By D uty Sheriff A.D SHERIFF'S RETURN - GARNISHEE CASES N0: 2006-06843 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND BENEFICIAL CONSUMER DISCOUNT VS STRAIT RAYMOND R ET AL And now STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:20 Hours, on the 11th day of April , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT STRAIT CYNTHIA K .00 .00 .00 .00 n n hands, possession, or control of the within named Garnishee M & T BANK 1 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BROOKE GRODIN (CUSTOMER REP) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this , in the true and made R. Thomas Kline Sheriff of Cumberland County 00 v y /1q J b1 4- 04/12/2007 ?7 day o f By Deputy Sheriff A.D WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6843 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 RAYMOND R. STRAIT AND CYNTHIA K. STRAIT, 11287 MOUNTAIN ROAD, ORRSTOWN, PA 17244 (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 M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA 17013 - ALL MONIES DUE DEFENDANTS 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 $12, 275.14 Interest $41.00 Atty's Comm % Atty Paid $287.85 Plaintiff Paid Date: MARCH 28, 2007 L.L. $.50 Due Prothy $2.00 Other Costs $50 DUE GARNISHEE - ?'?IuLq'kd -- Curti . Long, Px onota (Seal) By: Deputy REQUESTING PARTY: Name KURT J. WINTER, 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. 84801 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 85.99 Docketing 18.00 64.01 Poundage 1.69 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 04/30/08 Mileage 4.80 Misc. Surcharge 20.00 Levy -40.00 Post Pone Sale Certified Wl Po-urge &-) Gztahee 9.00 TOtkL 85.99 zr So Answers, R. Thomas Kline, She 'ff By ±? x Cellc VI o? 3 ?F3 '1 c ?C?U J 0 S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, vs. RAYMOND R. STRAIT AND CYNTHIA K. STRAIT, Defendant(s). Plaintiff's Address: 2700 Sanders Road Prospect Heights, IL 60070 CIVIL DIVISION: No. 06-6843-CIVIL TYPE OF PLEADING: Praecipe to Satisfy Judgment TYPE OF CASE: Civil Action FILED ON BEHALF OF: BENEFICIAL CONSUMER DISCOUNT COMPANY 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 BENEFICIAL CONSUMER DISCOUNT COMPANY, Plaintiff, VS. CIVIL DIVISION: No. 06-6843-CIVIL RAYMOND R. STRAIT AND CYNTHIA K. STRAIT, Defendant(s). PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please satisfy the judgment against RAYMOND R. STRAIT AND CYNTHIA K. STRAIT, at No. 06-6843-CIVIL, and mark the docket accordingly. Respectfully submitted, CHROMULAK & ASSOCIATES, L.L.C. By: 3bi 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 ay of , 2009. Notary Pu is COMMONWEALTH OF PENNSYLVANIA Notarkil =of Heather L Hatfield, Cell Twp., WaftMy COW FireMember, Pennsvivanla Association 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 13TH day of JULY 2009. RAYMOND R. STRAIT CYNTHIA K. STRAIT 11287 MOUNTAIN ROAD ORRSTOWN, PA 17244 4/- ? 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 O10TAINED WILL BE USED FOR THAT PURPOSE. FILLU -`7 PONRY OF THE PIP -' 2009 JUL 15 AM 11: 46 C r/? 4c -4 1-534C. J<A- X17 q ?