HomeMy WebLinkAbout07-0459s
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff
No. 07-459 Civil Term
vs.
TRACEY GLESSNER,
Defendant
TO THE CLERK OF SAID COURT:
CIVIL ACTION
PRAECIPE
Please enter judgment in favor of Plaintiff Commonwealth Financial Systems, Inc. and
against Defendant Tracey Glessner in the amount of $24,772.64 plus costs and interest at the rate
of 22.99% per annum from July 10, 2006, for want of filing an Answer. I certify that a 10-day
notice, a copy of which is attached hereto, was served on Defendant via first class mail on
February 21, 2007.
A4iiifk Mege, E
Attorney ID No. 81288
Attorney for Plaintiff
P.O. Box 1426
Bethlehem, PA 18016
(610) 954-5.93
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff
vs.
No. 07-459 Civil Term
CIVIL ACTION
TRACEY GLESSNER,
Defendant
TEN DAY NOTICE
TO: Tracey Glessner, 1437 Apple Circle, Apt A 190, Mechanicsburg, PA 17055
DATE OF NOTICE: February 21, 2007
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT
A HEARING AND YOU MAY LOSE YOUR MONEY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO YOUR 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
TELEPHONE (717) 249-3166
Algf. Mege, Esq.
Attorney ID No. 288
Attorney for Plaintiff
Law Offices of Alan R. Mege, Esq.
P.O. Box 1426
Bethlehem, PA 18016-1426
(610) 954-5393
IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA
Commonwealth Financial Systems,.lnc.
Plaintiff .
vs. NO. 2005-CV-4864-CV
Tracey Glessner
Defendant .
AFFIDAVIT OF NONMILITARY SERVICE
The undersigned, being duly sworn, according to law, deposes and says that the Defendant(s)
is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended;
That Tracey Glessner is over 18
years of age, resides at 1437 Apple Circle, Apt A 190, Mechanicsburg,- PA 17055
and is employed
That Defendant is
years of age, resides at
and is employed
That Defendant
IN
years of age, resides at
and is employed
That Defendant is
years of age, resides at
and is employed
I, Alan R. Wge, Esquire, do hereby verify that I am the attorney for Plaintiff, that I
am fully authorized to make this Verification on their behalf, that the Defendants are unavailable to
make this verification, that the facts contained in the foregoing pleading are true and correct to the best
of my knowledge, information and belief, and the source of my information are interviews with my
client and the Plaintiff's filed documents.
The verifier understands that false statements herein are made subject to the penalties
of 18 Pa. C.S. Section 4904 reI ' to unsworn falsification to authorities.
Signed:. _ Dated: 3/5/07
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff
vs.
TRACEY GLESSNER,
Defendant
No. 07-459 Civil Term
CIVIL ACTION
( ) Notice is hereby given that a Judgment in the above captioned matter has been
entered against you in the amount of $24,772.64 plus costs and fees on
7 , 2007.
( ) A copy of all documents filed with the Prothonotary in support of the within
judgment is/are enclosed.
othono
By:
If you have questions regarding this Notice, please contact the filing party:
NAME: Alan R. Wag, Esq.
ADDRESS: P.O. Box 1426
Bethlehem, PA 18016
TELEPHONE NO. 610-954-5393
(This Notice is given in accordance with Pa.R.C.P.§236.)
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff
VS.
TRACEY GLESSNER,
Defendant
: No. Civil Term O'r -l
CIVIL ACTION
NOTICE
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 ATTORNEYS 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 NY 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
TELEPHONE (717) 249-3166
Mege, EKK
Attorney ID N . Attorney for Plaintiff
Law Offices of Alan R. Mege, Esq.
P.O. Box 1426
Bethlehem, PA 18016-1426
(610) 954-5393
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff
VS.
TRACEY GLESSNER,
Defendant
No. Civil Term a''J d f S?
CIVIL ACTION
COMPLAINT
1. The Plaintiff is Commonwealth Financial Systems, Inc. ("CFSI"), a corporation
with an address of 120 North Keyser Avenue, Scranton, PA 18504.
2. The Defendant is Tracey Glessner ("Glessner"), an individual with an address of
1437 Apple Circle, Apt A 190, Mechanicsburg, PA 17055.
Count I - Breach of Contract
3. Defendant applied for and received a First USA credit card, account number 5417-
1126-5124-5309.
4. Use of the First USA credit card was subject to the terms of the Cardmember
Agreement ("Agreement"), a copy of which was sent to the Defendant along with the credit card.
A true and correct copy of the Agreement is attached hereto, made a part hereof and marked as
Exhibit "A".
5. Defendant used the First USA credit card account number 5417-1126-5124-5309
for purchases, cash advances, and/or balance transfers.
6. Defendant was mailed account statements relative to Defendant's use of the First
USA credit card.
7. The Defendant has defaulted under the terms of the Agreement by failing to make
monthly payments as they became due and owing.
8. The within account was sold by Bank One, Delaware, N.A., parent corporation of
First USA Bank, to Unifimd CCR Partners ("Unifund") for valuable consideration and all rights
under said account were assigned to Unifund, whereupon Unifund sold the within account for
valuable consideration to Plaintiff CFSI and all rights under said account were assigned to CFSI.
A true and correct copy of the Bill Of Sale and Bill Of Sale are attached hereto, made a part hereof
and marked collectively as Exhibit "B".
9. Pursuant to the terms of the Agreement, Plaintiff, upon default in payment, may
declare the entire unpaid balance immediately due and payable without notice or demand.
10. Pursuant to the terms of the Agreement, Defendant, is liable for interest on the
unpaid balance.
11. Pursuant to the terms of the Agreement, Defendant, is liable for Plaintiff s court
costs and reasonable attorneys fees.
12. As of July 10, 2006, the balance due and owing to Plaintiff from Defendant was
$19,818.11.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant,
in the amount of $19,818.11 plus costs and interest at the rate of 22.99% per annum from July 10,
2006 as well as reasonable attorneys fees of $4,954.53 and such other and further relief as the Court
may deem just and appropriate.
2
Count II - Account Stated
13. Plaintiff incorporates the allegations of every paragraph enumerated above of
this Complaint as if said paragraphs were fully set forth here at length.
14. The within account was an account in writing and expressly or impliedly accepted
by both parties.
15. The amounts due and owing to Plaintiff by Defendant are based on a subsisting
debt and arise from a preexisting account or course of dealing between the parties.
16. This account is an Account Stated, thereby operating to foreclose any dispute
over the amounts due.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant,
in the amount of $19,818.11 plus costs and interest at the rate of 22.99% per annum from July 10,
2006 as well as reasonable attorneys fees of $4,954.53 and such other and further relief as the Court
may deem just and appropriate.
Count III - Quantum Meruit
17. Plaintiff incorporates the allegations of every paragraph enumerated above of
this Complaint as if said paragraphs were fully set forth here at length.
18. The services provided by Plaintiff, described above, were received by the
Defendant, and the Defendant received and accepted the benefit of said services provided by
Plaintiff.
19. At all times material hereto, Defendant was aware that Plaintiff was
providing the aforesaid services to Defendant and expected to be paid for such.
20. At all times material hereto, Defendant, with the aforesaid knowledge,
3
permitted Plaintiff to provide the aforementioned services and incur damages.
21. At all time material hereto, the Defendant was unjustly enriched by
retaining the benefit of receiving said services without paying Plaintiff fair and reasonable
compensation.
22. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff's
expense, an implied contract exists between the Plaintiff and the Defendant, and the Defendant is
obligated to pay Plaintiff the value of the services described above and in the exhibits attached
hereto, in the amount of $19,818.11 plus costs and interest from July 10, 2006.
WHEREFORE, Plaintiff, requests judgment in its favor and against the Defendant,
in the amount of $19,818.11 plus costs and interest at the rate of 22.99% per annum from July 10,
2006 as well as reasonable attorneys fees of $4,954.53 and such other and further relief as the Court
may deem just and appropriate.
By:
Mege, Es re
AV1II?-
Attorney .. #812
for Plaintiff
P.O. Box 1426
Bethlehem, PA 18016-1426
(610) 954-5393
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EXHIBIT A
BILL OF SALE
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Bank One, Delaware NA ("Seller"), for value received and pursuant to the terms and
conditions of Credit Card Account Flow Purchase Agreement dated July 23, 2003
between Seller and Unifund CCR Partners, ("Purchaser"), its successors and assigns
("Credit Card Account Purchase Agreement"), hereby assigns effective as of the
Applicable Cut-Off Date of December 17, 2003 all rights, title and interest of Seller in
and to those certain receivables, judgments or evidences of debt described in Exhibit "1"
attached hereto and made part hereof for all purposes.
Number of Accounts 14,910
Total Unpaid Balances $87,215,859.74
Amounts due to Seller by Purchaser in hereunder shall be paid U.S. Dollars by a wire transfer to
be received by Seller on December 23, 2003 (the "Applicable Closing Date") by 3:00 p.m.
Seller's time, as follows: '
Bank One, Delaware NA
c/o Federal Reserve Bank-Philadelphia
ABA: 031 100 393
Account: 407253-1061000000
Attention: Marcos Castillo
This Bill of Sale is executed without recourse except as stated in the Credit Card
Account Purchase Agreement to which this is an Exhibit. No other representation of or
warranty of title or enforceability is expressed or implied.
SELLER: BANK ONE, DELAWARE BUYER: UNIFUND CCR PARTNERS
N.A.
By'
Title: ce President
Date: December 17, 2003
By:
Title: u1 1 ?%
Date: \ ?- • ?)?
?` n `1
4n!Fund
Unifund CCR Partners
BILL OF SALE
Unifund CCR Partners,' for value received and in accordance with the terms of the Accounts
Receivable Purchase Agreement by and among Unifund CCR Partners and Commonwealth
Financial Systems, Inc. ("Purchaser"), dated as of December 8, 2004 (the "Agreement'j, does
hereby sell, assign and transfer to Purchaser all of its good and marketable title, free and clean of
all liens, claims and encumbrances in and to the Accounts listed in the Account Schedule attached
as Appendix A to the`Agreement, without recourse and without representation or warranty of
collectibility, or otherwise, except to the extent stated in the Agreement.
Executed on ._5
UNIFUND CCR PARTNERS
By Credit Card Receivables Fund, Inc
Its General Partner
By David Rosenberg
President
S,
Fo
r unfund U se ONLY
Client # PID CID #
14
VERIFICATION
I, Patricia Cobb, Esquire, of Commonwealth Financial Systems, Inc.,
Plaintiff herein, do hereby verify that I am the keeper of records of the
Plaintiff in the foregoing civil action and that I am fully authorized to make
this verification and that the facts set forth in the Complaint are true and
correct to the best of my knowledge, information and belief.
Verifier understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to
authorities.
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PAT1ZICIA COBB
CFSI File No. 1-7o-70,5-2
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SHERIFF'S RETURN - REGULAR
CASE NO: 2007-00459 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COMMONWEALTH FINANCIAL SYSTEMS
VS
GLESSNER TRACEY
ROBERT BITNER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
r-_'T.L'QQNTWD TPArPV the
DEFENDANT , at 2004:00 HOURS, on the 31st day of January , 2007
at 1437 APPLE CIRCLE
MECHANICSBURG, PA 17055
JASON GLESSNER
APT A 190
by handing to
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.68
Affidavit .00
Surcharge 10.00
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
02/01/2007
ALAN MEGE
By:
eputy Sheri ft
A.D.
IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA
CIVIL DIVISION
Commonwealth Financial Systems, Inc.
V.
Tracey Glessner
Case No. 07-459 Civil Term
Amount Due $24,442.64
Interest from $5,220.63
22.99% from 7/10/06
Atty's Fee**
Costs to be added $174.00
PRAECIPE FOR WRIT OF EXECUTION
To the Clerk of Courts:
Issue a writ of execution in the above matter,
(1) direct the Sheriff of Cumberland county;
(2) against Tracey Glessner , defendant(s) and upon the
(Name of Defendant(s))
following described property of the defendant(s) All tanglible pgrsone,Lpmpaty of the defendant located at
1437 Apple Circle Apt 190, Mechanicsburg PA 17055
(Supply four copies of lengthy personalty list)
(if real property supply six copies of the description)
(3) against , garnishee(s) for the following property:
(4) and enter this writ in the judgment index
(a) against
defendant(s)
and
(b) against , as garnishee(s)
as a lis pendens against real property of the defendant in name of garnishee as follows:
Date: 6/14/07
Attorney for: Plaintiff
Telephone: (610) 95?
Supreme Court ID No:
** Where judgment has been entered under Rule 295l(a), attorneys' fees may be included if they are authorized
in the instrument and there has been a record appearance of counsel at any stage of the proceedings.
(Specifically described property)
Signature:
Print Name: R. Mee Esq./
Address: PO Box 1426, Beth em, PA 18016-1426
Pa.R.C.P. 3251
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-459 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COMMONWEALTH FINANCIAL SYSTEMS, INC.,
Plaintiff (s)
From TRACEY GLESSNER, 1437 APPLE CIRCLE, APT. 190, MECHANICSBURG, PA 17055
(1) You are directed to levy upon the property of the defendant (s)and to sell ALL TANGIBLE
PERSONAL PROPERTY OF THE DEFENDANT LOCATED AT 1437 APPLE CIRCLE,
APT. 190, MECHANICSBURG, PA 17055.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
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 $24,442.64
Interest FROM $5,220.63 - 22.99% FROM 7/10/06
Atty's Comm %
Atty Paid $128.68
Plaintiff Paid
Date: JUNE 18, 2007
L.L. $.50
Due Prothy $2.00
Other Costs
Curtis R. ong, Pr ry
(Seal)
By:
Deputy
REQUESTING PARTY:
Name ALAN R. MEGE, ESQUIRE
Address: PO BOX 1426
BETHLEHEM, PA 18016-1426
Attorney for: PLAINTIFF
Telephone: 610-654-5393
Supreme Court ID No. 81288
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff's Costs:
Docketing
Poundage
Advertising
Law Library
Prothonotary
Mileage
Surcharge
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage
TOTAL $
18.00
1.42
.50
2.00
9.68
20.00
20.00
.82 I?3?o-7
72.42 ? ?J So Answers;
o
R. Thomas Kline, Sheriff v
By 4CauJII-a'f-AI;. Brewbaker
Advance Costs: 150.00
72.42
$ 77.58
Refunded to Atty on 08/02/07
iZ :Z C" { Z LMI
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-459 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COMMONWEALTH FINANCIAL SYSTEMS, INC.,
Plaintiff (s)
From TRACEY GLESSNER, 1437 APPLE CIRCLE, APT. 190, MECHANICSBURG, PA 17055
(1) You are directed to levy upon the property of the defendant (s)and to sell ALL TANGIBLE
PERSONAL PROPERTY OF THE DEFENDANT LOCATED AT 1437 APPLE CIRCLE,
APT. 190, MECHANICSBURG, PA 17055.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
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 $24,442.64 L.L. $.50
Interest FROM $5,220.63 - 22.99% FROM 7/10/06
Atty's Comm % Due Prothy $2.00
Atty Paid $128.68 Other Costs
Plaintiff Paid
Date: JUNE 18, 2007
(Seal)
? ?ai4
Curtis X. Long, Pr otary
By:
REQUESTING PARTY:
Name ALAN R. MEGE, ESQUIRE
Address: PO BOX 1426
BETHLEHEM, PA 18016-1426
Attorney for: PLAINTIFF
Telephone: 610-654-5393
Supreme Court ID No. 81288
Deputy
i_
COUR7~ OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNS~'~'LVANIA
COMMONWEALTH FINANCIAL -~ d
~
~
SYS"I,EMS, INC. 3
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r=*~~
Plaintiff No. 07-459 Civil Term ~~ ~ ~
~ ~
' ~
CIVIL ACTION ~~
' - cam'
~
TRACEY GLESSNER, ~~ ~-. ~
Defendant `"~ "' -~
PLAINTIFF'S PRAECIPE TO UPDATE DEFENDANT'S ADDRESS
TO THE CLERK OF SAID COURT:
Please update Defendant's address to reflect: 70 McElwee Rd., Dauphin, PA ~ 70 ! 8
Date: Octobee 24.2012
Alan-~: Sege, Esq;~ ~
Attorney ID Nay 1288
" Attorney for~aintiff
P.O. Box 14~L6
Bethlehem, PA 18016
(610)954-5393
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA,
C
COMMONWEALTH FINANCIAL
rnW = rn =
SYSTEMS, INC. N o -urn
Plaintiff No. 07-459 Civil Term
,>
VS.
CIVIL ACTION ' ' :I-
TRACEY GLESSNER,
Defendant
PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO
INTERROGATORIES IN AID OF EXECUTION
And now comes Plaintiff and submits the instant Motion to Compel, and in support
thereof avers as follows:
1. Judgment for Plaintiff and against Defendant in the sum of$24,774.64 plus costs was
entered in Cumberland County on March 7, 2007.
2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class
mail on February 11, 2013.
3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were
due within thirty days after they had been served, but none has been received as of the date of
giving notice herein.
4. Counsel for Plaintiff has made a good faith effort to confer with Defendant, but
Defendant has still failed to reply.
5. A copy of this Motion and proposed Order were mailed to Defendant, via first class
mail on March 14, 2013. A certificate of Service is attached hereto as Exhibit"A".
6. As of March 14, 2013, Plaintiff has not received answers to the Interrogatories.
7. Plaintiff requires an Order pursuant to Pa.R.C.P. 4019 (a) (1) (I), compelling the
Defendants to answer the Interrogatories.
8. No Judge has ruled upon other issues in this matter.
9. Concurrence with the Pro Se Defendant has been sought and denied.
WHEREFORE, Plaintiff,requests that this Honorable Court grant its motion and
enter an Order directing the Defendant to answer Plaintiffs Interrogatories within twenty(20)
days or risk sanctions,pay fees in the amount of$100.00,as well as such other and further relief
as the Court may deem just and appropriate.
INL�- M E
6ge, s'
Attorney ID,No. 8 88
Attorney for PI� tiffs
P.O. Box 1426
Bethlehem, PA 18016-1426
(610)954-5393
-2-
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff No. 07-459 Civil Term
VS.
CIVIL ACTION
TRACEY GLESSNER,
Defendant
CERTIFICATE OF SERVICE
1, Alan R. M6ge, Esquire, hereby certify that on March 14, 2013, 1 served a true
correct copy of Plaintiffs Motion to Compel Defendant's Answers to Interrogatories in Aid of
Execution and proposed Order by mailing same,first class,postage prepaid to: Tracey Glessner,70
McElwee Rd., Dauphin, PA 17018.
By:
R Mtge,
—Atty. I.D. 481288
88
Attorney for Plainti f
P.O. Box 1426
70 East Broad St.
Bethlehem, PA 18016-1426
Jr .,
COMMONWEALTH FINANCIAL ,, 1��
SYSTERMS, INC.,
Plaintiff � �
V. IN THE COURT OF COMMON PLEAS
OF THE NINTH JUDICIAL DISTRICT
TRACEY GLESSNER,
Defendant 2007-00459 CIVIL TERM
IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO
INTERROGATORIES IN AID OF EXECUTION
Ice ORDER OF COURT
AND NOW, this j day of March 2013, upon consideration of Plaintiff's Motion
to Compel Defendant's Answers to Interrogatories in Aid of Execution, a RULE is issued
upon Defendant to show cause why the relief requested should not be granted.
PLAINTIFF shall effectuate service of this Order of Court upon Defendant. A
motion to make rule absolute will not be entertained until p roof of service is filed.
RULE RETURNABLE twenty (20) days from the date of service by Plaintiff.
No further relief is granted at this time.
BY THE COURT,
Thoma A. Placey C.P.J.
Distribution:
Alan R. Mege, Esq.
Tracey Glessner
i
I
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC. }
Plaintiff No. 07-459 Civil Term ,.
vs. U, I
CIVIL ACTION
TRACEY GLESSNER, '
Defendant
CERTIFICATE OF SERVICE
I, Alan R. Mege, Esquire, hereby certify that on March 28, 2013, I served a true
correct copy of the Court's March 26, 2013 Compel Order by mailing same, first class, postage
prepaid to: Tracey Glessner, 70 McElwee Rd., Dauphin, PA 17018.
By:
i R. M6ge, Esquir
Atty. I.D. #81288
Attorney for Plai iff
P.O. Box 1426
70 East Broad St.
Bethlehem, PA 18016-1426