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HomeMy WebLinkAbout03-1248vs "." t? I 5" c>3 - oq'p •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 X) D 'Q 1 w JU Cl) co't JJ ?? . 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. E w n n 49 -x C c ? ? C C ? vex- c .1 ?LJ 1/1 O C 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. p (.'. lH lXs "fin 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 O ? n U S L. _, .i. ,._? r- U,?, r? ?' ?, ?? ;-'7 c ., ` ? c: N n '; =1 'Jl ?p ? 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 n CD <D ? '7717' r- - ?o T9 Y TM j tjD 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* C3 N 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 O S N re Pdnt Clearly) itg be ompleted by mailer) m san R. MeaQ ------------ -------------- ----------------- Po Box No. o inet Mobile Estate - p ---- -------------------- Siew ZIP:4 ewville, PA 17241 -- ° o T .Y - (V rrt { ' ;..i 1 ^ti 11 al lD -C 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- ? ,V 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 E-?? V Sergea?t Uv Ca S, ((? -7 71 ,?33P7.3