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HomeMy WebLinkAbout02-5417IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HARLEY-DAVIDSON FINANCIAL SERVICES D/b/a HARLEY-DAVIDSON CREDIT Plaintiff(s) VS. PRAECIPE TO TRANSFER JUDGMENT OF POSSESSION AND MONEY KAREN M CLEMENS, individually and as Executrix of Estate of WILLIAM H CLEMENS, Deceased Defendant(s) FILED ON BEHALF OF Plaintiff(s) COUNSEL OF RECORD OF THIS PARTY: LORI A. GIBSON, ESQUIRE PA ID#68013 JON MCKECHNIE, ESQUIRE PA ID#36268 Bernstein Law Firm, P.C. Firm #718 1133 Penn Avenue Pittsburgh, PA 15222 412-456-8100 DIRECT DIAL: (412) 456-8114 BERNSTEIN FILE NO. R0017531 NOTICE THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HARLEY-DAVIDSON FINANCIAL SERVICES d/b/a HARLEY-DAVIDSON CREDIT, Plaintiff vs. Civil Action No. KAREN M. CLEMENS, individually and as Executrix of Estate of WILLIAM H. CLEMENS, Deceased, Defendant Prothonotary: PRAECIPE TO TRANSFER JUDGMENT Please transfer the within Judgment entered in The Court of Common Pleas of Lebanon County, Pennsylvania, known as No.2002-00859, and index it against the Defendant above named, in the amount of $9,794.14-0~ ~V~.~"x~,¥h,4~ ~ ~)O~'~-~'i~O/'~ 0'~ ~qq[/ Lebanon County costs to follow Judgment. BERNSTEIN LAW FIRM, P.C. LorT~ Gibson Attorney for Plaintiff 1133 Penn Avenue Pittsburgh, PA 15222 (412) 456-8100 We certify that the correct address of the Plaintiff is: c/o Bemstein Law Firm, P.C., 1133 Penn Ave., Pittsburgh, PA 15222 And the correct known address of Defendant is: 314 South 10th Street Lebanon, PA 17042 Date: 10/18/02 COURT OF COMMON PLEAS OF LEBANON COUNTY HARLEY-DAVIDSON FINANCIAL SERVICES D/B/A HARLEY-DAVIDSON CREDIT VS. KAREN M. CLEMENS, INDIVIDUALLY AND AS EXECUTRIX OF ESTATE OF, ET AL Action No. CERTIFICATION Time: 13:43:53 2002-00859 CIVIL DIVISION COMMONWEALTH OF PENNSYLVANIA: :ss COUNTY OF LEBANON : I, ~C~ ~A~fi~d¥ Prothonotary of the Court of Common Pleas of Lebanon County, Pennsylvania, do hereby certify that the above and foregoing pages contain a true copy and correct transcript of the docket entries, which form the whole record in the foregoing suit, and that Judgment has been entered and certified in favor of the Plaintiff and against the Defendant(s) in the sum of $9,794.14 IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed Seal of the said Court at Lebanon, Pennsylvania, this Eighteenth day of October, 2002. the Date: 10/18/02 COURT OF COMMON PLEAS OF LEBANON COUNTY Time: 13:43:53 HARLEY-DAVIDSON FINANCIAL SERVICES D/B/A HARLEY-DAVIDSON CREDIT VS. KAREN M. CLEMENS, INDIVIDUALLY AND AS EXECUTRIX OF ESTATE OF, ET AL Action No. 2002-00859 CIVIL DIVISION Docket Entries 1 through 8 6/21/02 COMPLAINT IN REPLEVIN, CONVERSION AND UNJUST ENRICHMENT, 834/0383 LORI A. GIBSON 6/21/02 SHERIFF SERVICE FILED. 7/02/02 SHERIFF'S RETURN, FILED. 837/0212 9/09/02 850/0473 9/09/02 850/0473 9/09/02 850/0473 PRAECIPE TO ENTER DEFAULT JUDGMENT IN THE AMT OF $9794.14 AND JUDGMEN~ FOR POSSESSION OF 1994 HARLEY DAVIDSON FXDWG MOTORCYCLE, SERIAL #1HD1G EL19RY308346, FILED. LORI A. GIBSON DEFENDANT NOTIFIED. LORI A. GIBSON NOTICE UNDER PRCP 237.1 FILED. 9/09/02 JUDGMENT ENTERED. 9/18/o2 852/o612 PRAECIPE FOR EXEMPLIFIED RECORD FOR IN-STATE USE, FILED. LORI A. GIBSON Date: 10/18/02 COURT OF COMMON PLEAS OF LEBANON COUNTY Time:13:43:53 HARLEY-DAVIDSON FINANCIAL SERVICES D/B/A HARLEY-DAVIDSON CREDIT VS. KAREN M. CLEMENS, INDIVIDUALLY AND AS EXECUTRIX OF ESTATE OF, ET AL Action No. 2002-00859 CIVIL DIVISION COMPLETE CAPTION Plaintiff(s) HARLEY-DAVIDSON FINANCIAL SERVICES 4150 TECHNOLOGY WAY CARSON CITY, NEVADA 89706 D/B/A HARLEY-DAVIDSON CREDIT Attorney LORI A. GIBSON Defendant(s) KAREN M. CLEMENS, INDIVIDUALLY AND AS 314 S. 10TH STREET LEBANON, PA. 17042 EXECUTRIX OF ESTATE OF, ET AL WILLAM H. CLEMENS, DECEASED Date: 10/18/02 COURT OF COMMON PLEAS F~kRLEY-DAVIDSON FINANCIAL SERVICES D/B/AHARLEY-DAVIDSON CREDIT VS. KAREN M. CLEMENS, INDIVIDUALLY AND AS EXECUTRIX OF ESTATE OF, ET AL OF LEBANON COUNTY Action No. INDEX ENTRIES Time: 13:43:53 2002-00859 CIVIL DIVISION Party Indexed as P. : HARLEY-DAVIDSON FINANCIAL SERVICES, ET AL First Opposing Party: KAREN M. CLEMENS, Comment : REPLEVIN Filed on: '0100100'' ' ' Microfilmed at: ET AL Judgment Amount: Party Indexed as P. : HARLEY-DAVIDSON CREDIT, ET AL First Opposing Party: KAREN M. CLEMENS, ET AL Comment . 'OiO6/60' : REPLEVI Filed on: Microfilmed at: Judgment Amount: Party Indexed as D. First Opposing Party Comment Filed on, 'O)O6/60' CLEMENS, KAREN M., ET AL HARLEY-DAVIDSON FINANCIAL SERVICES, ET AL REPLEVIN Microfilmed at: Judgment Amount: Party Indexed as D. : CLEMENS, WILLIAM H.(DECEASED), ET AL First Opposing Party: HARLEY-DAVIDSON FINANCIAL SERVICES, ET AL Comment Filed on: '0)06160': REPLEVIN Microfilmed at: Judgment Amount: Party Indexed as .. : CLEMENS, KAREN M. First Opposing Party: HARLEY-DAVIDSON FINANCIAL SERVICES, ET AL Comment . . : DEF JUDG/JUDG POSS Filed on: 9i0~/62 Microfilmed at: 850/0473 Judgment Amount: $9,794.14 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HARLEY-DAVIDSON FiNANCIAL SERVICES d/b/a HARLEY-DAVIDSON CREDIT, Plaintiff VS. KAREN M. CLEMENS, individually and as Executrix of Estate of WILLIAM H. CLEMENS, Deceased, Defendant Civil Action No. NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee Your are hereby notified that the following Order or Judgment was entered against you on II- '1 - 0~, . (xx) Assumpsit Judgment Count I possession of a used 1994 Harley-Davidson Motorcycle, Serial # 1HD 1 GEL 19RY308346, Count II & III Money Judgment in the amount of $9,794.14 plus costs. Karen M. Clemens 314 l0th Street Lebanon, PA 17042 () () Trespass Judgment in the amount of $ __ plus costs. If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (x) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PRO /ONOT^RW I EPUTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HARLEY-DAVIDSON FINANCIAL SERVICES D/b/a HARLEY-DAVIDSON CREDIT Plaintiff(s) No. 0o('- y~{~ OL~._~ VS. PRAECIPE FOR WRIT OF POSSESSION KAREN M CLEMENS, individually and as Executrix of Estate of WILLIAM H CLEMENS, Deceased Defendant(s) FILED ON BEHALF OF Plaintiff(s) COUNSEL OF RECORD OF THIS PARTY: LORI A. GIBSON, ESQUIRE PA ID#68013 JON MCKECHNIE, ESQUIRE PA ID#36268 Bemstein Law Finn, P.C. Firm #718 1133 Penn Avenue Pittsburgh, PA 15222 412-456-8100 DIRECT DIAL: (412) 456-8114 BERNSTEIN FILE NO. R0017531 NOTICE THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION HARLEY-DAVIDSON FINANCIAL SERVICES D/b/a HARLEY-DAVIDSON CREDIT Plaimiff vs. Civil Action No. KAREN M CLEMENS, individually and as Executrix of Estate of WILLIAM H CLEMENS, Deceased Defendant PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue Writ of Possession in the above matter for a used 1994 Harley-Davidson Motorcycle, Serial # 1HD1GEL19RY308346 located at 3810 Cedar Avenue, Camp Hill, PA 17011-6907. BERNSTEIN~ FIRM, P.C. Atto~nney for Plaintiff 1133 Penn Avenue Pittsburgh, PA 15222 (412) 456-8100 BERNSTEIN FILE NO. R0017531 WRIT OF POSSESSION (Ejectment Proceedings PRCP 3160 - 3165 etc.) Harley-Davidson Financial Services d/b/a Harley--Davidson Credit vs. Karen M. Clemens, individually ~,d ss Ex~cuLzix of Lh~ E~L~L~ of William Clemens, Deceased 3810 Cedar Avenue Camp Hill PA 17011-6907 No. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-5417 Civil Term Costs Term Att'y. $ 15.00 Pl'ff (s) $ Prothy. $ 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of CUMBERLAND County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: Harley-Davidson Financial Services d/b/a Harley-Davidson Credit Plaintiff (s) being: (Premises as follows): A Used Serial 1994 Harley-Davidson Motorcycle, # 1HD1GEL19RY308346 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. Date November 7, 2002 (SEAL) CURTIS R. LONG Prothonotary, Common Pleas Court of Gumberland County, Pennsylvania BY: ~/ Deputy ('0 0 (3 (1) ~ ~0 ~h By virtue of this writ, on the da3, of I caused the within named have possession of the premises described with the appurtenances, and ., tO Writ of Possession returned STAYED as per atty on 12/6/02 Sheriff's Costs Docketing $ 18.00 Advance Costs: $ 100.00 Poundage .98 Sheriff's Costs: 50.33 Prothontary 1.00 49.67 Milage 10.35 Surcharge 20.00 $ 50.33 Refunded to Atty on 12/9/02 Sworn and subscribed to before me this day of ~ Prothonotary