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HomeMy WebLinkAbout03-0247J V~ AUSTIN, BOLAND, CONNOR & GIORGI ' By Clemson N. Page, Jr., Esquire Pa. Atty. No. 25616 44 North Sixth Street P.O. Box 8521 Reading, PA 19603 [610] 374-8211 Fax [610] 372-2361 E-mail cnpagena,abcglaw.com AMERICAN GENERAL CONSUMER DISCOUNT COMPANY, Plaintiff . vs. DENNIS ETTER, Defendant. Attorneys for Plaintiff File No. 98007 (misc.) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. o~ z }~ 7 7~,U-,- CNIL ACTION-LAW PRAECIPE TO THE PROTHONOTARY: Kindly enter judgment by default in favor of American General Consumer Discount Company, Plaintiff, and against Dennis Etter, Defendant, and assess damages as follows: Damages per District Justice Judgment .................... $1,763.76 Costs of District Justice Action ............................. 82.00 TOTAL ..................................... 1 845.76 Together with interest from September 20, 2002. Attached hereto is the Notice of Judgment/Transcript entered in Case No. CV-400-02 before the Hon. Thomas A. Placey, District Justice, Magisterial District No. 09-3-04, Cumberland County, Pennsylvania. Dated: January 2, 2003. AUSTIN, BOLAI~, CONNOR & GIORGI By: Clemsdh N age, Jr.; Attorney r aintiff 10993.1 ~. K " ~ ~~ ~ ~~ ~ C ~ '_ t]"~ t'_' -. ~ ~ : ~ ~_'J C~.:_ . r ~ Ci3 : ~. (~ - y .tom / W • G 3, a-Y ! ~,~ ~,r...-. '` COMMONWEALTH OF PENNSYLVANIA couNTY oF: CvMe$R><~,Nn NOTICE QF JUDGMENT/TRANSCRIPT Mag. Dist. No.: PLAINTIFF: -CIVIL CASE NAME and ADDRESS 09 - 3 - 04 AMERICAN C~SNI3RAL CONS ....DISC. CO: ~ ": DJ Name: Hon. 125 GATEWAY DRIVE .THOMAS A. PLACEY SIIITE 109 address: 104 S. SPORTING HILL RD. ~MECHANICSBIIRG, PA 17055. MECHANICSBDRG, PA J VS. DEFENDANT: NAME and ADDRESS Tel~Phone. ~717> 761-8230 17050 rETTER, DENNIS -I 3 9 'POND ROAD NEWVILLE, PA 17241... AMERICAN GENERAL CONS. DISC. CO. L' -~ 125 GATEWAY DRIVE Docket No.: CV- 0000400 - 02 S'CTIfiE 109 Date Filed: 8/14/02 MECHANICSBURG, PA 17055 THIS IS TO NOTIFY YOU THAT: - ® Judgment was entered for: {Name) A>~RTCAw a~eAAr C.L1NS_ DISC C Judgment was entered against: (Name) rat, n~Ts in the amount of $ ~ ~ R4S 76 on: (Date of Judgment) q~~ g~Da Defendants are jointly and severally liable. (Date & Time) Damages will be assessed on: Amount of Judgment $ 1, 763.76 Judgment t/osts $ 82.00 Interest on Judgment $ • 00 This case dismissed without prejudice.. Attorney Fees $ . 00 Total.... $ 1, 845.76 Amount of Judgment Subject to Attachment/Act 5 of 1996. $ Post Judgment Credi#s $ Post Judgment Costs $ .Levy is stayed. for days or ~ generally stayed, __ ________ Certified Judgment Total $ Objection to levy has been#iled and hearing will be held: _. Date: Place: Time: ANY PARTY HAS THE RIGHT TO APPEAL. WITHIN 30 .DAYS AFTERtHE ENTRY OF JUDGMENT BY FILINGA NOTICE OF APPEAL WITH. THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEASi C1VIL DFVISION. YOU MUST INCLUDE A COPY OF THIS N E OF JUDG T MS RIPT F ORM WITWYOUR NOTICE OF APPEAL. Q ~- Date ,District Justice l certify that this is a true a corre ewe he p ceedings containing the judgment. q l l~~ Date ,District Justice - My commission expires first Monday of January, 2004 SEAL AOPG 315-99 F h ~~ ~. ~ ~ J w ~ ~ ~ ~` ~ Ic G W ~, } ~ ~- i C~ ~~ '~ f S y 'x C o - _ c_ ., , 5 ~: . ~~ a, - , , ~:~ ~ ~ c ; u; _ _ ' ~ ~ -~- `~ c ~ ~ _ W ;,~;Tk ~ ~a- ~ ~ ~,` 0 w J ..' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: AMERICAN GENERAL CONSUMER DISCOUNT CO. 125 Gateway Drive Suite 109 Mechanicsburg, PA 17050-2905 vs. Dennis Etter 39 Pond ~t Newville, PA 17241 TO THE PROTHONOTARY OF THE SAID COURT: ( )Confessed Judgment ( )Other File No. 0 3- ~ ~7 r~~c',P "~~ Amount Due $1, 845.76 Interest Atty's Comm Costs The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) PPrRnna 1 Prnr~Prty PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and a~~ other property of the defendant(s) in the possession,. custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens agai re tate of the defendant(s) described in the attached exhibit. ~I , ~~i~~ Date January 13, 2003 Signature: Print Name: Clemso~~~age,~„ Esquire Austi O rid _nr ~. (_i orgl Address: ~c. N.,,-r~, c;Yth--_St~eet P.O. Box 852E Attorney for: Plaintiff Telephone: _610-374-s21 ~ Supreme Court ID No.: 25616 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. .~ t:..,; w L?;! r~K, ~_ ~ ~ .. ~ ,p ~„ ~ ( ~~ : ~d ~ ~ ~ ~ ~ ~ ~., a , a.. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N003-247 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN GENERAL CONSUMER DISCOUNT COMPANY Plaintiff (s) From DENNIS ETTER 39 POND ROAD, NEWVILLE PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession ofl 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$1845.76 Interest Atty's Comm Atty Paid $ Z.50 Plaintiff Paid $34.25 Date: JANUARY 16, 2003 (Seal) L.L.$0.50 Due Prothy $1.00 Other Costs CURTIS R LONG Prothono~ta~ry~,, ~ ~ Deputy REQUESTING PARTY: Name CLEMSON N PAGE, JR ESQ AUSTIN BOLAND CONNOR & GIORGI Address: P. O BOX 8521 READING PA 19603 Attorney for: PLAINTIFF Telephone: 610-374-8211 Supreme Court ID No. 25616 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N003-247 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN GENERAL CONSUMER DISCOUNT COMPANY Plaintiff (s) From DENNIS ETTER 39 POND ROAD, NEWVILLE PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell PERSONAL PROPERTY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 1 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) Ifpvoperty 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$1845.76 Interest L.L.$0.50 Atty's Comm Atty Paid $ 2.50 Plaintiff Paid $34.25 Due Prothy $1.00 Other Costs Date: JANUARY 16, 2003 (Seal) CURTIS R. LONG Prothonot ~ By: ~~.2Q.~,.~ Deputy REQUESTING PARTY: Name CLEMSON N PAGE, JR ESQ AUSTIN BOI.AND CONNOR & GIORGI Address: P. O BOX 8521 READING PA 19603 Attorney for: PLAINTIFF Telephone: 610-374-8211 Supreme Court ID No. 25616 ~~ ~,, r s R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing $ 18.00 Poundage 3 6.91 Advertising Law Library . 5 0 Prothonotary 1.00 Mileage g ; 2 g Misc. Surcharge 2 0.0 0 Levy 20.00 Post Pone Sale Garnishee Sworn and Subscribed to before me This ~ day of 200 A.D. Prothonotary Advance Costs: 150.00 Sheriff's Costs: 104.69 Refunded to Atty on 2 / 7 / 0 3 0 c~ So Ans ers• R. Tho as Kline, Sheriff BY ~r•Qu~1~x ~~ ~~ ,~ ;., .. _..~ e:.-.-:.:•.r -=:.:y ,~ DC.k~ 3 9 ~ (.3 /cc.e., ;s'7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~ CIVIL DIVISION FILE NO: 2003-00247 AMERICAN GENERAL FINANCIAL SVCS, INC. 125 GATEWAY DRIVE SUITE 109 MECHANICSBURG, PA. 17050-2905 VS. DENNIS B. ETTER 39 POND ROAD NEWVILLE, PA. 17241 PRAECIPE AND POWER OF ATTORNEY FOR SATISFACTION AND/OR TERMINATION TO THE PROTHONOTARY OF SAID COURT: You are hereby authorized, empowered, and directed to enter, as indicated, the following on the records thereof: A. 1. The within suit is Settled, discontinued, Ended and costs paid. 2. The within suit is Settled, Discontinued, Ended WITH Prejudice and costs paid. 3. The within suit is Settled, Discontinued, Ended WITHOUT Prejudice and costs paid. B. 1. Satisfaction of the Award in the within suit is acknowledged. 2. XXX3t Satisfaction of Judgment, with interest and costs, in the within matter is acknowledged. C. 1. Q"tlier: ~ _ ._ DAT13:y '• ~_"k'E>~Rt1ARY 14 , 2003 vituac L. ar1~,t,A, ar. t L.C.A. MY COMMISSI N EXPIRES: AUGUST 10, 2 06 Traci A. Gorse Notary Public Traci q _ Seal Notary PiubUc COST PAYMENT VERIFICATION ~ Expk,sa County ~uD. 10. I UNDERSTAND THAT THE ABOVE ACTION CANNOT BE FILED AND DOCKETED UNTIL ALL COSTS , INCLUDING SHERIFF'S COSTS; AND HEREBY VERIFY THAT ALL COSTS HAVE BEEN PAID. I UNDERSTAND THAT FALS STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SEC.4904 RELATING TO UNSWOR~i FALSIFICATION TO AUTHORITIES. ~--~~--~ E ark D..Spit~ei~ ~ ` L.C.A. 1 C~ (w 17 ~~ .G ~ ~~ ~~ ~r ._ S- - ~~ f r`~ r~ . v