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HomeMy WebLinkAbout03-0818Brigid Q. Alford, Esquire Supreme Court I.D. #38590 BOSWELL, T1NTNER, PICCOLA & WICKERSHAM 315 N. Front Street P.O. Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 Attorneys for Plaintiff GRANDVIEW SURGERY & LASER CENTER AT MECHANICSBURG, PLAINTIFF Ve JOHN BRETZ, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA .. · No. 0 3-- : : CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: KINDLY ENTER JUDGMENT in favor of Plaintiff and against the Defendant John Bretz, in the amount of $2,936.98, plus interest at the legal rate of 6% and costs of suit, pursuant to the judgment granted by District Justice Robert V. Manlove. I hereby certify that no appeal has been made. BOSWELL, TINTNER, PICCOLA & WICKERSHAM By: Brigid Q. ~Alford,'Es-q~ir~ DATE: February 24, 2003 COMMONWEALTH OF PENNSYLVANIA COUNTY'OF: CUMBE~ Mag. Dist. No.: 09-3 -05 DJ Name: Hon. C-,AYLE A. El,DER ^d~ress: 507 ~N. YORK ST. MECHANICSBURG, PA Telephone: (717) 766-4575 17055 ATTORNEY FOR PLAINTIFF : BRIGID Q. ALFORD ESQUIRE 315 N FRONT ST PO BOX 74! HARRISBURG, PA 17108-0741 THIS IS TO NOTIFY YOU THAT: Judgment: D]~FAIILT NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE ' ' NAME and ADDRESS ~GRANDVIEW SURGERY & LASER CNTR/MEC~ 179 LANCASTER BLVD. C -NICSBURG, PA 17O55 09- VS. 0EFENOANY: NAME and ADDRESS [-BRETZ, JOHN ~ 208 LOCUST STREET CAMP HILL, PA 17011 Docket No.: CV- 0000305 - 02 Date Filed: 10/38/02 JUDGM~m]T PLTF ~-~ Judgment was entered for: (Name) [~ Judgment was entered against: (Name) in the amount of $ ~.: ~_3~; _ 9~ on: Defendants are jointly and severally liable. (Date of Judgment) (Date & Time) Damages will be assessed on: This case dismissed without prejudice. Amount of Judgment Subject to Attachment/Act 5 of 1996 $_ Amount of Judgment $ 2,836.48 Judgment Costs $ 100.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2,936.98 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WiTH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEASAND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMP. LIESWITH THE JUDGMENT. My c°mmission exPireS first Monday of January, 2006 . AOPC 315-03 SEAL GRANDVIEW SURGERY & LASER CENTER AT MECHANICSBURG, PLAINTIFF JOHN BRETZ, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : : CIVIL ACTION - LAW TO: JOHN BRETZ, DEFENDANT You are hereby notified that on February 24, 2003, judgment has been entered against you in the above-captioned case in the amount of $2,936.98, plus interest at the legal rate of six (6%) percent, plus costs of suit. DATE: February 24, 2003 Prothonotary I hereby certify that the following is the address of the Defendant stated in the Certificate of Residence: John Bretz 208 Locust Street Camp Hill, PA 17011 TO: JOHN BRETZ, DEFENDANT Pot este medio se le esta notificando que el February 24, 2003, el siguiente Fallo ha sido antodo en contra suya en el caso mencionado en el epigrafe. FECHA: February 24, 2003 Protonotario Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado de residencia: John Bretz 208 Locust Street Camp Hill, PA 17011 GRANDVIEW SURGERY & LASER CENTER AT MECHANICSBURG, PLAINTIFF JOHN BRETZ, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : : CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE I hereby certify that the addresses of the parties in the above-captioned action are as follows: Grandview Surgery & Laser Center at Mechanicsburg 179 Lancaster Blvd. Mechanicsburg, PA 17055 Plaimiff John Bretz 208 Locust Street Camp Hill, PA 17011 Defendant BOSWELL, TINTNER, PICCOLA & RSHAM Denise L. Foster, Paralegal IN THE COURT OF OEM~DN PLEAS OF ~RRLAND COUNTY, PEaR, SYLVANIA GRANDVIEW SURGERY & LASER CENTER AT MECHANICSBURG, PLAINTIFF DEFENDANT JOHN BRETZ, CIVIL DMSION : File No. 03-- ~/f ~if : Amount Due 2,936.98 : Interest AT THE LEGAL 6% from ///~'/~L~ Atty's Comxn : Costs TOT HE PROTHONOTARY OFT HE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, c6ntract, 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. PRAEEIPE FOR EXECUTION 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) Levy on all personal property, including furniture, appliances, televisions, VCR's, entertainment equipment, sports equipment, computers, located at: 208 LOCUST STREET, CAMP HILL, PA 17011 PRAECIPE FOR ATTAC~M~ 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 all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index tb/s writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. February 24, 2003 Signature: Print Name: Address: DATE: Brigid Q. Alford,~squire 315 N. Front Street/PO Box 741 Harrisburg, PA 17108-0741 Attorney for: Plaintiff Telephone: (717) 236-9377 Supreme Court ID No.: 38590 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF pENNSYLVANIA) NO 03-818 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Grandview Surgery & Laser Center at Mechanicsburg Plaintiff (s) From John Bretz 208 Locust Street Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell Levy on all personal property, including furniture, appliances, televisions, VCR's, entertainment equipment, sports equipment, computers, loated at: 208 Locust Street, Camp Hill, PA 17011. (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 $2,936.98 Interest at the legal 6% from 1/15/03 Atty's Comm % Atty Paid $36.75 Plaintiff Paid Date: February 24, 2003 (Seal) L.L.$.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary. ,~ Deputy REQUESTING PARTY: Name Brigid Q. Alford, Esq. Address: 315 N. Front Street, PO Box 741 Harrisburg, PA 171080741 Attorney for: Plaintiff Telephone: 717-236-9377 Supreme Court ID No. 38590 IN THE coURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION OSI, FUNDING LLC, ASSIGNEE OF COMPUCREDIT ACQUISITION FUNDING Plaintiff VS. COMPLAINT IN CIVIL ACTION DERECK T. JADRO Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#02648672 TRUE COPY FROM RECORD ~ t~ ~1 ~ ~i~ ~I ~ Carlisle, ~. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CWIL DIVISION OSI, FUNDING LL(,:, ASSIGNEE OF COMPUCREDIT ACQUISITION FUNDING Plaintiff VS. DERECK T. JADR© Defendant Civil Action No. COMPLAINT IN CIVIL ACTION AND 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 aF. pearance personally or by an attorney and filing in writing with the court your defenses or objectiom~ to the claims set forth against you. You are warned that if you fail to d° 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ',. COMPLAINT \ Plaintiff is a corporation with offices in P.O. Box 2388 Doraville, Georgia 30362-2388. o Defen:tant is an adult individual residing at 49 Lincoln Street, Enola, PA 17025. o Defenilant applied for and received a credit card issued by Plaintiff's assignor beating the account number 479 i'060111699137. 4. Defen'4ant made use of said credit card and has currently a balance due and owing to Plaintiff, as of July ,-7; 2001, in the amount of $2,509.93, as shown by Plaintiff's Statement of Account attached hereto, mark...ed as Exhibit "1" and made a part hereof. 5. Defen3:lant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff'thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is entitled to the additiofi of finance charges at the rate of 6% per annum on the unpaid balance. i 7. Plaintiff avers that finance charges calculated at the aforesaid rate from July 7, 2001 to October 22, 2002 ami)unt to $194.74. 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges, attorneys' fees or any part thereof to Plaintiff. 7 WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Dereck T. Jadro individually, in the ~nount of $3,119.91 with continuing finance charges thereon at the rate of 6% per annum plus costs. · THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAlX~, WEINBERG & REIS, CO.,_ L.P.A. PA I.D. #47437 ~/ WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:02648672 OM Funding, LLC LITIGATION NETWORK Post Office Box 2388 Doraville, Georgia 30362-2388 800-945-0007 JULY 31, 2002 DERECK T JADRO 20 BUCK RD DOVER, PA 17315-2066 STATEMENT OF ACCOUNT Debtor's Name: OSI Funding LLC Acct Number: Original Creditor: Original Account Number: Write OffDate (Charge OffDate): Principle Balance: Balance Due: Interest Rate: DERECK T JADRO 3952218611 COMPUCREDIT ACQUISITION FUNDING 4791060111699137 07/07/01 $2,509.93 $2509.93 33. % EXfllEtffl- WWW VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S..~4904 relating to unsworn falsifications to authorities, that he/she is ~__...~~ ~-, ILl (Name) LI~L~ /",i¢,j~LV~-F- of ~)._~1 ~-14-,',)b~N¢o, L,L~.C. , plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. (Signature) Ww~ 02648672 R. THOMAS KLINE Shedff EDWARD L, SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Deputy May 22, 2003 Grandview Surgery & Laser Center of Mechanicsburg vs John Bretz No. 2003-818 Civil Term Property Claim Determination Dear Sir, Reference is made to Property Claim dated May 12, 2003, entered by Lurena Phillips, pertaining to Writ of Execution No. 2003-818 Civil Term, Grandview Surgery & Laser Center of Mecharficsburg. R. Thomas Kline, Sheriff, has determined that the claimant, Lurena Phillips, in the above mentioned property claim, is prima facie the owner of the property set forth therein. So Answers: CC; Brigid Alford, Atty for Pltff John Bretz, Deft. Lurena Phillips, Claimant PROP~.:~RTY CLAIM In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 0¢_ · TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned, A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE TItF~CLAI~ANT OBTAINED TITLI~ TO THE PROPF~TY AS FOLLOWS: State of P~ylva~a: CounW of C~berland above l~t in ~e prop~ cla~ ~re ~ect ~d ~e, Expires April 4, 2005 being duly sworn according to law, deposes a' ~/Claimant PROPERTY CLAIM In the Court of Common Pleas of Cumberland County, Pennsylvania W tNo. '-t~?lTz /~a_. , /TbT/--- TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE :CLAIM~.ANzT OBTAINED TITLI~ TO THE PROPERTY AS FOLLOWS: Date ___ State of Pennsylvania: County of Cumberland above list in the property claim, are correct and hue. My Commission Expires April4, 2005 being duly sworn according to law, deposes and says that the  : Claimant -- /6.00 (/de.. ~7 6DO 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: Docketing 18.00 Poundage 1.37 Advertising Law Library .50 Prothonotary 1.00 Mileage 8.97 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee TOTAL 69.84 Advance Costs: 200.00 Sheriff's Costs: 69.84 130A6 Refunded to Atty on 12/18/03 Sworn and Subscribed to before me this '? - day of~_~ pr6thfonotary ' i,fo