HomeMy WebLinkAbout03-1248vs "." t? I 5"
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•COMMONWEALTH OF PENNSYLVANIA
(`ni KITV nF• CUMBERLAND
Mag. Dist. No.:
09-3-02
DJ Name: Han.
HELEN B. SHULENBERGER
Address: P.O. BOX 155
27 W. BIG SPRING AVENUE
NEWVILLE, PA
Telephone: (717 ) 776 - 3187 17241
PRA III, LLC
PO BOX 356
C/O BURTON NEIL & ASSOC
WEST CHESTER, PA 19381
THIS IS TO NOTIFY YOU THAT:
Judgment:
0 Judgment was entered for:
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
rPRA III, LLC
PO BOX 356
C/O BURTON NEIL & ASSOC
PST CHESTER, PA 19381 J
VS.
DEFENDANT: NAME and ADDRESS
rMEAD, SUSAN R 7
148 CONDODOGUINET
MOBILE EST
LNEWVILLE, PA 17241 J
Docket No.: CV-0000154-02
Date Filed: 11/21/02
(Name) PRA TTT T-T r
® Judgment was entered against: (Name) mRAn, sQsAN R
in the amount of $ 402g4_27 on
? 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 $_
(Date of Judgment) 12/1 n l"
(Date & Time)
Amount of Judgment $ 4,171.27
Judgment Costs $ 113.00
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ 4,284.27
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 PLEAS AND 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 COMPLIES WITH THE JUDGMENT.
1241O Lo Z Date District Justice
I certify that this is a true and correct copy of the record of the proceedings containing the judgment.
U Date dlylXiFn 4,? , District Justice
T
My commission expires first Monday of January, 2006. SEAL
AOPC 315-03
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. COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: Cumberland
Mag. Dist. No.:
09-3-02
DJ Name: Hon.
Helen B. Sholenberger
Address: 27 W. Big Springs Rd, Box 155
Newville, PA 17241
Telephone: 717-776-3187
AMOUNT DATE PAID
FILING COSTS $
POSTAGE $
SERVING COSTS $
CONSTABLE ED. $
TOTAL $
CIVIL COMPLAINT
PLAINTIFF: NAME and ADDRESS
F PRA III, LLC
c/o Burton Neil 8t Associates, P.C.
I_PO Box 356 West Chester, PA 19381-0356
VS.
DEFENDANT: NAME and ADDRESS
rSUSAN R. MEAD
148 Condodoguinet Mobile Est
LNewville, PA 17241
Docket No.:
Date Filed:
TO THE The above named plaintiff(s) asks judgment against you for 4171.27 together with
DEFENDANT: costs upon the following claim (Civil fines must include citation of the statute or ordinance
violated):
For past due balance incurred on a credit card, originally issued to $3,337.02 Principal
Defendant by Direct Merchants which debt Plaintiff later acquired, plus $.00 Interest
attorneys fees per terms and conditions of account. $834.25 Attorneys Fees
$.00 Credit
$4,171.27 Balance
I, Burton Neil, Esquire, Atty for Plaintiff, verify that the facts set forth in this complaint are true and
correct to the best of my knowledge, information and belief. This statement is mad t to the penalties of
Section 4904 of the Crimes Code (18 PA. C. S. § 4904) related to unsworn fal ' tion to a horities.
qjqw*Wrlaintikor Authorized Agent)
Plaintiffs
Attorney:
Telephone:
Burton Neil
610-696-2120
Address: PO Box 356
West Chester, PA 19381-0356
IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE
TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO,
JUDGMENT WILL BE ENTERED AGAINST YOU BY DEFAULT.
If you have a claim against the plaintiff which is within district justice jurisdiction and which you intend
to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before
the date set for the hearing. If you have a claim against the plaintiff which is not within district justice
jurisdiction, you may request information from this office as to the procedures you may follow. If you
are disabled and require assistance, please contact the Magisterial District office at the address
above.
AOPC 30BA-02
BURTON NEIL & ASSOCIATES, P.C.
By: Burton Neil, Esquire
Identification No. 11348
26 South Church Street
West Chester, PA 19382
610-696-2120
Attorney for Plaintiff
PRA III, LLC
PO Box 61597
VA Beach, VA 23466
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
SUSAN R. MEAD
148 Condodoguinet Mobile Est
Newville, PA 17241
Defendant
: NO. 03 /.?q p
: CIVIL ACTION - LAW
Certification of Address and
Affidavit of Non-Military
Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating
to unsworn falsification to authorities, I verify that:
1. The above are the precise last-known addresses of the judgment creditor and debtor.
2. The said defendant is not in the Military Service of the United States or its Allies or otherwise within
the coverage of the Soldiers' and Sailors' Relief Act of 1940, as amended, is over 18 years of age and has a
civilian occupation.
B N IL & ASSOCIATES, P.C.
By:
Burton Neil, Esquire
Attorney for Plaintiff
In making this communication, we advise that our firm is a debt collector.
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
Pa.R.C.P. & 3103 to 3149
PRA III, LLC
Plaintiff
IN THE COURT OF COMMON PLEAS
vs.
SUSAN R. MEAD
Defendant(s)
FARMERS NATIONAL BANK
Garnishee(s)
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-1248 CIVIL
CIVIL ACTION - LAW
To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER
1. Directed to the Sheriff of Cumberland County, Pennsylvania
2. against SUSAN R. MEAD , Defendant(s)
3. and against FARMERS NATIONAL BANK , Garnishee(s)
4. and index this writ
(a) against Defendant(s)
(b) against Gamishee(s)
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as
follows: (specifically describe property)
NO LEVY-GARNISHMENT ONLY
Serve interrogatories on garnishee at: 1 West Big Spring Avenue, Newville, PA 17241
5. Amount Due $4,284.27
Interest from 12/10/02 $ 73.26
Total $4,357.53*
*Plus writ costs
Dated: March 24, 2003 t..
Burton eil, Esquire
Attorney or Plaintiff
NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county
should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the count
in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as
authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule
3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis
pendens is desired. See Rule 3104(c).
The firm of Burton Neil & Associates, P.C. is attempting to collect a debt.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-1248 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PRA HI, LLC, Plaintiff (s)
From SUSAN R. MEAD, 148 CONDOGUINET MOBILE EST., NEWVILLE, PA 17241
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of FARMERS NATIONAL BANK, 1 WEST BIG SPRING A%?ZZ, I LE, PA 17241
GARNISHEE(S) as follows: SERVE INTERROGATORIES ON Ge+ a+?31
and to notify the gamishee(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 $4,284.27
Interest FROM 12/10/02 - $73.26
Atty's Comm %
Arty Paid $37.25
Plaintiff Paid
Date: NNE 24, 2003
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothonotary n
(Seal) /JO
Deputy (((???
REQUESTING PARTY:
Name BURTON NEIL, ESQUIRE
Address: BURTON NEIL & ASSOCIATES, P.C.
THE TOWNE HOUSE
26 SOUTH CHURCH STREET
P.O.BOX 356
WEST CHESTER, PA 19381-0356
Attorney for: PLAINTIFF
Telephone: 610-696-2120
Supreme Court ID No. 11348
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2003-01248 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PRA III LLC
VS
MEAD SUSAN R
And now DAWN L. KELL Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0010:34 Hours, on the 30th day of June , 2003, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
MEAD SUSAN R
hands, possession, or control of the within named Garnishee
FARMERS NATIONAL BANK 1 WEST BIG SPRING AVE
NEWVILLE, PA 17241
Cumberland County, Pennsylvania, by handing to
DOUG LINDSAY (SALES MANAGER)
, in the
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to His
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
.00
So answ s•
R. Thomas Kline
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
By
this day of
02 t rv-33AA.D.
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Pr t onotary
?akk-rn Deputy Sheriff ?tL
BURTON NEIL & ASSOCIATES, P.C.
By:Burton Neil, Esquire - Id. No. 11348
26 South Church Street
West Chester, PA 19382 - 610-696-2120
Attorney for Plaintiff
PRA III, LLC
Plaintiff
vs.
SUSAN R. MEAD
Defendant(s)
FARMERS NATIONAL BANK
Garnishee(s)
To: FARMERS NATIONAL BANK
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-1248 CIVIL
CIVIL ACTION - LAW
A,.>sW6" -lo
Interrogatories to Garnishee
1 West Big Spring Avenue, Newville, PA 17241
You are required to file answers to the following Interrogatories within twenty (20) days after service
upon you. Failure to do so may result in judgment against you.
1. At the time you were served or at any subsequent time, did you owe the defendants any money or
where you liable to it by virtue of monies held by you on deposit or otherwise on any negotiable or written
instrument or did defendants claim that you owed them money or were liable to them for any reason.
No.
2. At the time you were served or at any subsequent time, was there in your possession, custody or
control or in the joint possession, custody or control of yourself and one or more other persons any property of
any nature owned solely or in part by the defendants?
No.
3. If the answer to 1 and/or 2 is yes, please specify the nature of the property and, if money, the amount?
N/A
4. At the time you were served or at any subsequent time, did you hold legal title to any property of any
nature owned solely or in part by the defendants or in which defendants held or claimed interest?
No
5. At the time you were served or at any subsequent time, did you hold fiduciary any property in which
the defendants had an interest?
No.
6. At the time before or after you were served, did the defendants transfer or deliver any property to you
or to any person or place pursuant to your direction or consent and if so, what was the consideration therefor?
No.
7. At any time after you were served, did you pay, transfer or deliver any money or property to the
defendants or to any person or place pursuant to its direction or otherwise discharge any claim of the defendants
against you?
No. ,,
BURTON Ell, & ASSOCIATES, P.C.
By:
-• 13u n ei1, Esquire
The firm of Burton Neil & Associates, P.C. is attempting to collect a debt.
VERIFICATIOF
The undersigned verifies that the answers contained herein are true and correct.
The undersigned understands that false statements herein are made subject to the
penalties of 18 Pa. C.S. 54904, relating to unsworn falsifications to authorities.
FARMERS NATIONAL BANK OF NEWVILLE, a Division
Y NA TIONAL BANK
JnADAMS?'COUN
Date: July 7, 2003 BSIIJ( y?'
e wyn, sistant Vice President
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PRA III, LLC, No. 03-1248 CIVIL
Plaintiff,
V.
SUSAN R. MEAD, ATTACHMENT EXECUTION
Defendant, PROCEEDINGS
and
FARMERS NATIONAL BANK,
Garnishee.
CERTIFICATE OF SERVICE
AND NOW, this 10th day of July, 2003, I, Edward G. Puhl, Esquire, of Puhl,
Eastman & Thrasher, attorney for Garnishee, Farmers National Bank of Newville, a division
of Adams County National Bank, hereby certify that I have this date served Garnishee's
Answers to Interrogatories, by mailing a true copy first class mail, postage prepaid, to Burton
Neil, Esquire, at the address shown below:
BURTON NEIL & ASSOCIATES, P.C.
26 South Church Street
West Chester, PA 19382
PUH?L, EASTMAN & THRASHER
By ! ?l 14'?c.c lf?f
Edward G. Puhl, Esquire
Attorney ID #55709
Attorney for Garnishee
220 Baltimore Street
Gettysburg, PA 17325
(717) 334-2159
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PRA III, LLC, No.03-1248 CIVIL
Plaintiff,
V.
SUSAN R. MEAD,
Defendant,
and
FARMERS NATIONAL BANK,
Garnishee.
ATTACHMENT EXECUTION
PROCEEDINGS
PROOF OF NOTICE TO DEFENDANT
COMMONWEALTH OF PENNSYLVANIA,
COUNTY OF ADAMS.
On this, the 10" day of July, 2003, before me, a Notary Public, in and for said
Commonwealth and County, the undersigned officer, personally appeared Edward G. Puhl,
Esquire, attorney for Farmers National Bank of Newville, a division of Adams County
National Bank, the Garnishee in the above entitled attachment execution proceedings, who
having been by me duly sworn, according to law, on his oath, does depose and say that on
July 10, 2003, he forwarded to the Defendant, Susan R. Mead, a copy of the writ issued in
said proceedings on June 24, 2003, and a copy of the answer to Interrogatories Fanners
National Bank of Newville, a division of Adams County National Bank, Garnishee, filed in
said proceedings, by mailing the same certified mail deposited at the post office in
Gettysburg, Adams County, Pennsylvania, addressed to the Defendant at the following
address: 148 Condoguinet Mobile Estate, Pennsylvania 17241.
Attached to this Proof of Notice is the certified mail receipt showing the aforesaid
mailing of the items hereinbefore mentioned.
?6"444?2
Edward G. Puhl, Esquire
Sworn to aqd subscribed before me
this 10 Ch day of July, 2003.
Y 14t bt - •? 'u?/tom
Notary Public
NOTARIAL SEAL
My commission expires: LAURA M. SMITH, 801sry 1`011110
8011ysburlBoro,Adams
ON*
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Ln Susan R. Mead
60
t
$ MAILED
age
.
Pos 7/ 10/03
M Certified Fee 2.30 Postmark
a
Return Receipt Fee
Her=
N (Endorsement Required)
C3
C3
flesldc[ed Celivery Fee
C3 (Endorsement Requiretl)
M Total Postage & Fees $ 2.90
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m san R. MeaQ
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Po Box No.
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ewville, PA 17241
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BURTON NEIL & ASSOCIATES, P.C.
By Burton Neil, Esquire
Identification No. 11348
26 South Church Street
West Chester, PA 19382
610-696-2120
Attorney for Plaintiff
PRA III, LLC
IN THE COURT OF COMMON PLEAS
Plaintiff
VS.
CUMBERLAND COUNTY, PENNSYLVANIA
SUSAN R. MEAD
Defendant
NO. 03-1248 CIVIL
FARMERS NATIONAL BANK
Garnishee : CIVIL ACTION - LAW
Praecipe to Dissolve Attachment Against Garnishee
To the Prothonotary:
Mark the Attachment against the above-named Garnishee dissolved.
BURTON& ASSOCIATES, P.C.
urton Neil, Esquire
Attorney for Plaintiff
71-
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PRA III LLC
Vs
Susan R. Mead
Writ of Execution
Docket No. 2003-1248 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED. No action has been taken in the last six months.
Sheriffs Costs
Docketing $18.00
Surcharge $20.00
Levy $20.00
Mileage $ 7.59
Poundage $ 1.52
Prothonotary $ 1.50
Garnishee $ 9.00
Total $77.61 ,/ /j))g169 (?-
So Answers:
? f:
R. Thomas Kline, Sheriff
BY
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