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HomeMy WebLinkAbout00-00388 >.8\ .._~j . _."=_.~, ~ ,,~, "~ 'liIlMIIiIIiIillilIIi "O~ ....1~". t"'" - ~ COMMONWEALTH OF PENNPI"\.VANIA COUNTY OF: CUMBER~ Mag. Dist. No.: 09-3-04 DJ Name: Hon. , ',' THOMAS A. PLACEY A""'''104 S. SPORTING HILL RD. MECHANICSBURG, PA 'T,'eph". (717) 761-8230 17055 PA S'l'ATE EMPLOYEES CREDIT UNION 1 CREDIT UNION PL HARRISBURG, PA 17110 ,. ~ 1!i THIS IS TO NOJIFY YOU THAT: Judgment: [i] Judgment was entered for: ..,.. _W' ,. _....."'~,~""-"""^'0.. 7'lb. ;unr-o. 3 S.f C;;:...e T ~ NOTICE <C)JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rpA STATE EMPLOYEES CREDIT UNION I 1 CREDIT UNION PL HARRISBURG, PA 17110 L ~ VS. DEFENDANT: NAME and ADDRESS 'cLAPPER, BETTY J 9 CREEKSIDE LN. CAMP HILL, PA 17011 L Docket No.: CV-0000635-98 Date Filed: 12/15/98 I ~ DEFAm.T .:JUDGMRNT PLTF (Name) 1>1>. l'lTI>.TR RM1>T.nVRRl'l C'.RRnTT TThTTn [i] Judgment was entered against: (Name) C'.T.I>.1>1>RR, RRTTV ,T inthe amount of $ ?,7R1 n? on: o o o o o o Defendants are jointly and severally liable. Damages will be assessed on: This case dismissed without prejudice, Amount of Judgment Subject to Attachment! Act 5 of 1996 $ Levy is stayed for days or D generally stayed, Objection to levy has been filed and hearing will be held: Date: Place: Time: (Date of Judgment) 1 /?t; /qq . . (Date & Time) Amount of Judgment $ 2.719.02 Judgment Costs $ 62.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2.781.02 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTH RY/CLERK OF THE COURT OF MMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COP THIS N TI OF JUDGMENT RIPT FORM WITH YOUR NOTICE OF APPEAL. J -,4 (" . q::L Date I certify that this is a true and co hl (., -'1 C) Date My commission expires first Monday of Janu ry, AOPC 315-96 """"".'1)':,.': , DistrictJustice s COntaining the judgment. , District Justice 2004 SEAL ~~ -.\ "'" - - ~~'t&'l!-~~ii!leiiIiIJiii1~J'!I"it,&..HlfLll.i<iblli'id~'t1t111'!I'~""-"""..'- Q .... o ~ "~"~ ~ ""~ ~,. "'.~"ilW . ~-" ~ J rr 0 0> 0 ~ C 0 -n :;:;: , ~ '"0 CD "" mrri Z ::.: ~ Z::C; g~ Z1" N ~ (f) '" i:~(' C) 0 '.'-1.,) ;<: "., :;]:=R ~8 :3: (:.,?o lJ.' > om C C() ~ ~ "" 00 -< l f ~ r ~ \, 'll - .. ,l: l\ ~ ~ ~ '" V\ \' ,t '" " ~ fl , ~ --.. PENNSYL VANIA STATE EMPLOYEES CREDIT UNION, Plaintiff Vs. BETTY J CLAPPER, Defendant "'.<."'.Th~ .'. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. CV-0000635-98 Patricia A Kelly Account Advisor Pennsylvania State Employees CU P.O, Box 67013 Harrisburg, P A 17106-7013 (800) 237-7328 Ex!.: 3117 ,.I~', .,~ , '\ " \ '\; \, '~" ~ , .~~;!" PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, BETTY 1. CLAPPER, Defendant NO, 2000-00388 CIVIL ACTION - LAW PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Steven C. Courtney, Esquire, of Metzger, Wickersham, Knauss & Erb, P .C" on behalf of the Plaintiff, Pennsylvania State Employees Credit Union. By C, Courtney, Esquire ey I.D, No, 74669 3211 orth Front Street P,O, Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: ~ Document #: ]80134.1 8 c:; c:;.) 7'c;'" S ~~:f! - z:-.,~'I t'V Z c- "2 i ~t , i 'C) '.'i~'?, , ; ~.,~ I >'"c 1'0 ;, -y -'- r- i -< .-l , , I ! '!~ 1:1 :i' ,""'c ' " ~~,~. . . ~l7'.:T. .,..~ ~:""~'~ ,~:wJ " < ~ I. II!':;';. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANLASTATE EMPLOYEES CREDIT UNION, Plaintiff No. 2000-00388 v CIVIL ACTION - LAW BETTY J, CLAPPER, Defendant ORDER AND NOW, this _ day of , 2001, upon consideration of Plaintiff's Motion to Compel Discovery, it is hereby ORDERED and DIRECTED that: 1. Defendant is to appear for an oral deposition and bring all of the requested documents; 2. The oral deposition of Defendant shall be conducted on the 2200 day of February, 2001, at 9:00 a.m., at the law office Metzger, Wickersham, Knauss & Erb, P.C., 3211 North Front Street, Harrisburg, Pennsylvania 17110; 3, Defendant be held in contempt and require to so pay Plaintiff the reasonable expenses of preparing and presenting this Motion in the amount of $150,00; 4. The amount set forth in paragraph "3" shall be added to the judgment amount owed by the Defendant; and 5. such other relief as the Court may deem necessary. BY THE COURT, J, Document#:19507~1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff No, 2000-00388 v CIVIL ACTION - LAW BETTY J, CLAPPER, Defendant RULE AND NOW, this 2S" day of ~ "') ,2001, upon consideration of the foregoing Motion, it is ORDERED that the parties to this action show cause, if any they have, why this Motion should not be granted. RULE RETURNABLE "Z 0 ,. days from the date of service hereof, BY THE COURT: 1. ~~ O/-:l5-t) I I ~Xsi Document #: 195075.1 '_"~ ~ -~~ 1- - " ~ ~ IIId _.. ~...L.",~~, ,-" '" , "~^ .~ ~~ .. .., ",.~.., - i. ,"' ^''''O' ~. '" ,~., ~ ,~, , .. 1';';'.":';"'''li'' "",,,,, . ~ '.'" .1, ~..,. ."i On "," ""'"""J " , nc ~"I r""r ""'r', .." ~r .... i"!'~tJ.,J-Ut-rICt :~:Onf'~);lJOr,~,r:!y OI,J.4N25 Pf13:30 CUMBERLlWD COUNTy PENNSYLVANIA ~ D ,,, " " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff No, 2000-00388 v CIVIL ACTION - LAW BETTY J. CLAPPER, Defendant MOTION TO COMPEL AND NOW, this IX- day of ~ ,2001, comes the Plaintiff, Pennsylvania State Employees Credit Union, through its attorneys Metzger Wickersham Knauss & Erb, P,C, and files this Motion To Compel Discovery pursuant to Rule 4019 of the Pennsylvania Rules of Civil Procedure, and in support thereof avers the following: 1. Plaintiff, Pennsylvania State Employees Federal Credit Union, is a Pennsylvania Corporation doing business within the Commonwealth of Pennsylvania and the other states of the United States with its principal place of business situated at One Credit Union Place, Harrisburg, Pennsylvania 17110, 2, Defendant, Betty J. Clapper, is an adult individual with a last known address of 9 Creekside Lane, Camp Hill, Pennsylvania 17011, 3. On, January 21,2000, a Judgment was entered in favor of Plaintiff and against Defendant in the Common Pleas Court of Cumberland County, Pennsylvania, with respect to the above captioned matter. A true and correct copy is attached herein, incorporated hereto and marked as Exhibit "A". Document #: 195075.1 :.,".".~,,_. - . "~ ~~-~- -- 4. Thereafter, on or about October 25,2000, Defendant was properly served with a Notice of Deposition and a Subpoena requesting that Defendant appear for an oral deposition on Monday, November 20,2000, and bring along the requested documents, A true and correct copy of the Notice of Deposition and the Subpoena is attached hereto, incorporated herein and collectively marked as Exhibit "B", 5. Despite receiving notice of the time and place of the deposition pursuant to Rule 4007,1 of the Pennsylvania Rules of Civil Procedure, Defendant failed to appear for said deposition. 6, Despite numerous efforts, through both telephone contact and written correspondence, Defendant refuses to respond or get in contact with the undersigned concerning said deposition. 7. To date, Defendant has not responded to Plaintiff's request for the designated materials or appear for oral deposition, WHEREFORE, Plaintiff respectfully request this Honorable Court to issue an Order: a, compelling Defendant to appear for oral deposition and bring the requested documents; b. holding Defendant in contempt and requiring Defendant to pay Plaintiff the reasonable expenses incurred in connection with preparing and presenting this Motion in the amount of $150.00; c, The amount set forth in paragraph "b" shall be added to the judgment amount owed by the Defendant; and Document #: 195075.1 .'~' 'I ", -- _,e d. granting any other relief with regard to Defendant's failure to make discovery as is just and proper. Respectfully Submitted, D,re II (0A Steven . ou E quire Attorney J.D. No, 74669 3211 North Front Street P,O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document #: 195075.1 r~~ il IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff No, 2000-00388 v CIVIL ACTION - LAW BETTY J. CLAPPER, Defendant VERIFICATION I, Steven C. Courtney, Esquire verify that the statements made in the foregoing Motion to Compel Discovery are true and correct to the best of my knowledge, information and belief, I understand that false statements are made subject to the penalties of 18 Pa,C,S. Sec. 4904 relating to unsworn falsification to authorities, D,,, // fol Steve ey, uire Document#:19507~1 'ill! - - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff No. 2000-00388 v CML ACTION - LAW BETTY 1. CLAPPER, Defendant CERTIFICATE OF SERVICE I, Steven C. Courtney, Esquire, do hereby certify that I served on thetL- day of January, 2001, copy of the Order from the Motion to Compel in the above captioned matter first class mail, postage prepaid, upon the following individual: Betty J, Clapper 9 Creekside Lane Camp Hill, P 17011 Steven C. Courtney, Es 're Attorney I.D, No, 74669 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document #: 195075.1 -'~~-r"' - -~.- - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, No. 2000-0388 Plaintiff vs, CIVIL ACTION-LAW BETTY J, CLAPPER, Defendant RULE AND NOW, this ~ day of ~Att..'-1 , 2001, upon consideration of the foregoing Motion, it is ORDERED that the parties to this action show cause, if any they have, why this Motion should not be granted. RULE RETURNABLE I~ days from the date of service hereof, BY THE COURT: 7- /1;/ J, ~~~ 03-14 -0 RKS Document #: 199650.1 ,,:,~ ~ ~ '"'I""!I"!....I"~, , , - 'H ~ ~ ......C,,', , . :;',,~ "'c.., . , "';"";,';';""';:c,.."'" ',; ; "J; ..,;,;",j, ",[:;;;",;c<c." ' ,,__ <~ FllED-.OFFlCE 0::: 'iLl::: PP"'I'Li(')"I07i-Any , .j I,~, . ,''-~ r l... 1\; I\fl 01 P1M 14 AllII: 50 CUMSEh1.ANP COUNT'(y PENNSYLVANIA ,.",,;,,,, ,__ ,.,:CC' "..' . . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, No. 2000-0388 Plaintiff vs, CML ACTION-LAW BETTY J. CLAPPER, Defendant ORDER AND NOW, this _ day of ,2001, upon consideration of Plaintiff's Motion for Contempt, it is hereby ORDERED and DIRECTED that: a. Defendant are in willful contempt of this Court's Order dated January 25,2001; b, The oral deposition of Defendant shall be conducted on the 10" day of April, 2001, at 9:00 a,m., at the law office Metzger, Wickersham, Knauss & Erb, P,C" 3211 N. Front Street, Box 5300, Harrisburg, Pennsylvania 17110; c. Defendant is required to pay Plaintiff the reasonable expenses of preparing and presenting this Motion in the amount of $150,00; d, The amount set forth in paragraph "c" shall be added to the judgment amount owed by the Defendant, in addition to the previously awarded attorney's fees; e. In the event that the Defendant does not comply with paragraph "b", it is directed that a civil attachment will be issued for the Defendant during normal court hours from 8:30 a,m. to 4:30 p.m,; f. In the event that the Sheriff's Office would serve the civil attachment after those hours, the Defendant would be notified that they should appear at the next session of the Court's Civil Court; g. Such other relief as the Court may deem necessary. BY THE COURT: J. Document #: J 99650.1 !"~ r--I ~ "~ ~ "n..", '1 ! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, No. 2000-0388 Plaintiff vs. CML ACTION-LAW BETTY 1. CLAPPER, Defendant MOTION FOR CONTEMPT AND NOW, this? day of March, 2001, comes the Plaintiff, Metzger, Wickersham, Knauss & Erb, P.C., through its attorney, Steven C. Courtney, Esquire and files this Motion for Contempt, and in support thereof avers the following: 1. Plaintiff, Pennsylvania State Employees Federal Credit Union, is a Pennsylvania Corporation doing business within the Commonwealth of Pennsylvania and the other states of the United States with its principal place of business situated at One Credit Union Place, Harrisburg, Pennsylvania 17110. 2. Defendant, Betty J. Clapper, is an adult individual with a last known address of 9 Creekside Lane, Camp Hill, Pennsylvania 17011. 3, On, January 25,2001, an Order was entered in the above captioned matter providing that Defendant appear for an oral deposition on February 22,2001 at 9:00 A,M. 4. Thereafter, on or about February 5, 2001, a copy of the Order was mailed to the Defendant by certified mail, return receipt requested and first class mail, postage prepaid. 5, The certified letter enclosing the Order was received by the Defendant as evidenced by the executed return receipt card, A true and correct copy of the return receipt Document #: 199650.1 ."'--r ~" ~"~... ~- --= card is attached hereto, incorporated herein marked as Exhibit" A" , 6, Despite receiving letter enclosing the Order, Defendant has failed to pay attorney's fees in the amount of $150.00 awarded by this Court pursuant to the Order. 7, Despite receiving a copy of the Order providing for the date, time and place of the oral deposition, Defendant failed to appear for said deposition. 8. Defendant is in willful contempt of the Court's Order dated January 25, 2001. 9, Plaintiff has incurred reasonable attorney's fees and costs in preparing and presenting this Motion. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order granting Plaintiffs Motion for Contempt and order the following: a. Defendant is in willful contempt of this Court's Order dated January 25,2001; b, Defendant shall appear at the law office of Metzger, Wickersham, Knauss & Erb, P.C., 3211 North Front Street, Harrisburg, Pennsylvania 17110 for purposes of an oral deposition; c. Defendant is required to pay Plaintiff the reasonable expenses of preparing and presenting this Motion in the amount of $150,00; d. The amount set forth in paragraph "c" shall be added to the judgment amount owed by the Defendant, in addition to the previously awarded attorney's fees; e. In the event that the Defendant does not comply with paragraph "b", it is directed that a civil attachment will be issued for the Defendant during normal court hours from 8:30 a.m. to 4:30 p,m.; f. In the event that the Sheriff's Office would service the civil attachment after Document#: 199650.1 :.;.~~". I", . -. -., ~...,. "'1 those hours, the Defendant would be notified that they should appear at the next session of the Court's Civil Court; g. such other relief as the Court may deem necessary, Respectfully Submitted, Date: J ~~ S n C. C sq METZGER WICKERS 3211 N, Front Street Box 5300 Harrisburg, PA 17110 (717) 238-8187 LD, No, 74669 Attorney for Plaintiff & ERB, P,C, Document #: 199650.1 !i,~_._.~ r' ~., ~,'''''''''',' '" "!IIl'R!!I ." ~ ,- !"::;;',~.fIO''''" VERIFICATION I, Steven C. Courtney, Esquire verify that the statements made in the foregoing Motion to Compel Discovery are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to Date: ,NUl Document #: 199650.1 1- .- -- ~ -~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, No, 2000-0388 Plaintiff vs. CML ACTION-LAW BETTY J. CLAPPER, Defendant CERTIFICATE OF SERVICE I, Steven C. Courtney, Esquire, do hereby certify that I served on the l-- day of March, 2001, copy of the Order from the Motion for Contempt in the above captioned matter fIrst class mail, postage prepaid, upon the following individual: Betty J, Clapper 9 Creekside Lane Camp Hill, PA 17011 1'\ 5S & ERB, P,C, Document #: 199650.1 1'..!:1(;". I ~ ~- , ~" ~ ~ r'- SENDER: COMPLETE THIS SECTION . Complete itemS' 1 '; -2~ and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: Betty J Clapper 9 Creekside Lane Camp Hill, PA 17011 [ i.tJ~ -Z'1K) 2. Article Number (Copy from service label) ,~ 1 P.lsdel' ad diff item 11 If YES, enter delivery address below: o Agent o Addressee DYes D No ~ 3. Service Type KI Certified Mail o Registered o Insured Mail o Express Mail :i' Return Receipt for Merchandise DC,Q,D, 4. Restricted Delivery? (Extra Fee) Dyes 7099 3400 0014 1832 2036 10259S.QQ-M.Q952 PS Form 3811, July 1999 Domestic Return Receipt .~,!~ I __o<Il~I~~~ ~......."'--"""'..._".,,-"""'-'"'~~ .,' --- -~"~""""""- - " ,'"""""",,,, ,~_A', " ~q"! ' (;1'" "',' . ;.,c.:~ ti ~s; .:.(i",- H~l:9 ~ ~ -, . .,,"p.r... ,.~~ 0' ~ """ 7.1 I 0:> -0 ::; ,0' , ~'~"l -. ~im n~'-- _ r-- :~1 ~~~S _i-"'t', _~"f"l C)-- 2;0 l":..:t:.fT1 j -4 ~ '< f.>' o- r:- ...! '" "' ~., I) "" I Godfrey & Courtney, P.C. BY: Steven C. Courtney, Esquire Attorney I,D, No, 74669 P.O. Box 6280 HarriSburg, PAl 7112 Attorney for Plaintiff (717) 540-3900 PENNSYLVANIA STATE EMPLOYEES: IN THE COURT OF COMMON PLEAS CREDIT UNION : CUMBERLAND COUNTY, : PENNSYL VANIA Plaintiff VS. NO. 2000-00388 BETTY J. CLAPPER Defendant CIVIL ACTION -LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please satisfY the Judgment that was entered against the Defendant in the above captioned matter. Respectfully submitted, GODF By: Dated: 8.22,2003 Steven C. ourtney, Esquire ID # 74669 P.O, Box 6280 Harrisburg, PA 17112 717-540-3900 Attorney for Plaintiff Document #: 218597.1 - ~~~~~;_OJ!/Ol ..L "-'-" . ~ ~= '~._'i (') 0 0 C W -n :s:: ;Do '-l rilW, C ~ z:~, GJ 'i1'i;I;! Z~c 'N <"om :{Jj,> c;t> "'6 ,.~ ~t;' <:J ..--! ~ K " ".. i5;q ~D :x :sO S? zO C om ~ 0 ~ -< C- -< "