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Home My WebLink About99-06829No. 9?- ?a 9 Civil Term o?QO - VS. d Court of Common Pleas Cumb. Co. ` COMMONWEALTH OF PENNSYLVANIA IC O??NOTICE OF JUDGMENTITRANSCRIPT CUMBERLAND CIVIL CASE 09-1-01 DJ N=8: Hon. CHARLES A. CLEMENT, JR. A&mss; 1106 CARLISLE ROAD CAMP HILL, PA T„,p,aM,(717) 761-4940 17011 ACTION MGMT INC/NORTH'D NATL BANK P.O.BOX 276 ELYSBDRG, PA 17824-0276 PLAINTIFF: NAME and ADDRESS 5ACTION MGMT INC/NORTH'D NATL BANK , P.O.BOX 276 ELYSBURG, PA 17824-0276 L J VS. DEFENDANT: NAME and ADDRESS rDEETZ, SR., DAVID D. 950 ORCHARD AVE. CAMP HILL, PA 17011 L J DocketNo.: CV-0000294-98 Date Filed: 7/14/98 4 ,• THIS IS TO NOTIFY YOU THAT: noun m ^ ?,,.,n..vu, n or mu Judgment: ® Judgment was entered for: (Name) ' FXJ Judgment was entered against: (Name) in the amount of $ gig-c;7 on: (Date of Judgment) WSW ? Defendants are jointly and severally liable. (Date & Time) Damages will be assessed on: Amount of Judgment Judgment Costs Interest on Judgment This case dismissed without prejudice. Attorney Fees Total E] Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Post Judgment Credits Past Judgment Costs Levy is stayed for days or F-1 generally stayed. ^ .r.-J L.J.....nnlT E] Objection to levy has been filed and hearing will be hIl Date: Place: ?j • AUG ? 0 ,493 I Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT F ITH YOUR NOTICE OF APPEAL. 8-18-98 Date District Justice I cedity that this is a true an mact copy of t c d o e proceediEQ ntai 'ng the judgment. 8-18-98 Date District Justice S My commission expires first Monday of January, 2002 AOPC 315.96 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA ACTION MANAGEMENT INC. NORTHUMBERLAND NATIONAL BANK Plaintiff VS. DEETZ, SR.; DAVID D. Defendant NO. CIVIL ACTION- LAW ENTRY OF APPEARANCE Respectfully Submitted, Daniel F. Wolfson, Esq e WOLFSON M ASSOCIATES, P.C. 267 E. Market Street York, Pennsylvania 17403 Please enter the appearance of Daniel F. Wolfson, Esquire as the Attorney for the Plaintiff. Date:'YlO-U-Cim C' `j 199 Telephone No. (717) 846-1252 Attorney I.D. # 20617 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ACTION MANAGEMENT INC. NORTHUMBERLAND NATIONAL BANK Plaintiff vs. NO. DEETZ, SR., DAVID D. Defendant NOTICE OF ORDER, DECREE OR JUDGMENT TO: ( ) PLAINTIFF (X) DEFENDANT ( ) GARNISHEE ( ) ADDITIONAL DEFENDANT YOU ARE HEREBY NOTIFIED THAT THE FOLLOWING ORDER, DECREE OR JUDGMENT HAS BEEN ENTERED AGAINST YOU ON IN ACCORDANCE WITH THE PROVISIONS OF PA.R.C.P. 236 ( ) DECREE NISI INEQUITY ( ) FINAL DECREE IN EQUITY (X) JUDGMENT OF ( ) CONFESSION ( ) VERDICT (X) DEFAULT () NON-SUIT ( ) NON-PROS () ARBITRATION AWARD () JUDGMENT IS IN THE AMOUNT OF S PLUS COSTS. S FOR A TOTAL OF S (X) DISTRICT JUSTICE TRANSCRIPT OF JUDGMENT IN CIVIL ACTION IN THE AMOUNT OF S746.07 PLUS COSTS $72.50 FOR A TOTAL OF $818.57 ( ) IF NOT SATISFIED WITHIN SIXTY (60) DAYS. YOUR MOTOR VEHICLE OPERATOR'S LICENSE WILL BE SUSPENDED BY THE PENNSYLVANIA DEPARTMENT OF TRANSPORTATION PROTHONOTARY BY I! IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE' NTACT: NAME OF (ATTORNEY/FILING PARTY) ADDRESS: TELEPHONE NUMBER: WOLFSON & ASSOCIATES, P.C. 267 EAST MARKET STREET YORK, PENNSYLVANIA 17403 (717) 846-1252 OR 800.321.8467 i •- c_• 1 LT 1 `J f ACTION MANAGEMGN'I', : IN T111:000RT OP COMMON PLEAS OP INC., : CUM13FRLAND COUNTY, PENNSYLVANIA Plaintiff N'. : CIVIL AC'T'ION - LAW DAVID D. DEETZ, SR., Del'endant NO. 99-6829 CIVIL TERM ORDER 01: COURT AND NOW, this 31" day of March. 2000, upon consideration of Plaintiff's Motion To Remove As Counsel, no one having appeared I'or the hearing scheduled for this date on the motion, and the court concluding that the motion is not opposed, Daniel F. Wolfson and the law firm of Wolfson & Associates. P.C., are excused froth further participation as counsel in this case. Plaintiff's attention is called to Walaeataige v. Excell, 2000, Inc., 331 Pa. Super. 137, 480 A .2d 281 (1984) (representation of corporation in judicial proceedings by person wlio is not a lawyer prohibited). BY -rI-IE COURT, Harry A. Strausser, Jr. Action Management, Inc. P.O. Box 276 58 West Valley Avenue Elysburg, PA 17824 Plaintiff Daniel 1. Wolfson. Esq. 267 East Market Street York, PA 17403 Plaintiff's Counsel of Record 4 J. . eslcy Ole J. ra f r,.i 3 David D. Dcct-r_, Sr. 204 Producc Road R.R.#3 Selinsgrove, PA 17870 Defendant, Pro Se :rc ?' - nw!am O? AC'T'ION MANAGI:MI N'1'. IN'1'111- COIJII'1' OF COMMON PI_I:AS OI' INC.. CIJMIDI:RI,AND COUNTY. PENNSYLVANIA Plaintiff N,. : CIVILACT'ION-LAWA BY THE COUR'T'. DAVID D. DELETZ_. SR.. Defendant NO. 99-6829 CIVIL TERM ORDL'R OF COURT AND NOW, this tAay of March. 2000. upon consideration of Plaintiffs Motion To Remove As Counsel.a hearing is scheduled for Friday. March 31. 2000, at 2:45 p.m., in Courtroom No. I, Cumberland County Courthouse. Carlisle. Pennsylvania. Harry A. Strausser, Jr. Action Management, Inc. P.O. Box 276 58 West Valley AVCmIe Elysburg, PA 17824 Plaintiff Daniel F. Wolfson, Esq. 267 Last Market Street York. PA 17403 Plaintiffs Counsel of Record David D. Deetz. Sr. 204 Produce Road R.R.#3 Selinsgrove. PA 17870 Defendant. Pro Se 4vesle. Olcr.,l. J. U ? rcrc ? :re Action Management, Inc. 58 West Valley Avenue, P.O. Box 276 Elysburg, Pennsylvania 17824-0276 VAR <? /, Joao C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION MANAGEMENT, INC., Plaintiff NO: 99-6829 CIVIL ACTION - LAW VS. DAVID D. DEETZ, SR. District Justice Charles A. Clement, Jr. District Ct No: 09-1-01 CV #294-98 Defendant RULE TO SHOW CAUSE AND NOW, this day of , 2000, upon the consideration of the foregoing Motion, it is ORDERED that the parties to this action show cause, if any they have, why this Motion should not be granted. RULE RETURNABLE days from the date of service hereof. BY THE COURT: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION MANAGEMENT, INC., Plaintiff VS. DAVID D. DEETZ, SR. Defendant : ORDER NO: 99-6829 CIVIL ACTION - LAW District Justice Charles A. Clement, Jr. District Ct No: 09-1-01 CV #294-98 AND NOW, TO WIT, this day of 2000, it is ORDERED, ADJUDGED and DECREED that the appearance of DANIEL F. WOLFSON, ESQUIRE and the law firm of Wolfson & Associates, P.C., as counsel for the Plaintiff, Action Management, Inc., be removed from the above captioned action. BY THE COURT: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION MANAGEMENT, INC., NO: 99-6829 Plaintiff VS. CIVIL ACTION - LAW District Justice Charles A DAVID D. DEETZ, SR. Clement, Jr. District Ct No: 09-1-01 Defendant CV #294-98 PRAECIPE TO REMOVE AS COUNSEL Please remove the appearance of DANIEL F. WOLFSON, ESQUIRE as counsel for the Plaintiff in the above captioned action. DATED: HARRY, RAUSSER,JR. President and CEO Action Management, Inc. P 0 Box 276 58 West Valley Avenue Elysburg PA 17824 (570) 672-9732 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION MANAGEMENT, INC., NO: 99-6829 Plaintiff CIVIL ACTION - LAW Vs. District Justice Charles A. Clement, Jr. DAVID D. DEETZ, SR. District Ct No: 09-1-01 Defendant CV #294-98 MOTION TO REMOVE AS COUNSEL ?? ?I ?/ ^ AND NOW, TO WIT, this6day of 1 4 Lz , 2000, comes HARRY A. STRAUSSER, JR., President and CEO of Action Management, Inc. and files the within Motion for the following reasons: 1. On or about JULY 14, 1998, Plaintiff, Action Management, Inc., commenced this action by filing a Complaint in the Court of Common Pleas of Cumberland County. 2. On or about NOVEMBER 22, 1999, Daniel F. Wolfson, Esquire and the law firm of Wolfson & Associates, P.C. entered his/their appearance on behalf of Plaintiff, Action Management, Inc., to represent them in connection with this and various other actions. 3. Daniel F. Wolfson, Esquire and the law firm of Wolfson & Associates, P.C. has not represented Action Management, Inc. in a manner to protect its interest regarding this valid debt. 4. Daniel F. Wolfson, Esquire and the law firm of Wolfson & Associates, P.C. have withdrawn at his/their will from twenty-nine (29) other Action Management, Inc. cases. 5. On or about February 9, 2000, Action Management, Inc. received a letter dated February 7, 2000 wherein Daniel F. Wolfson, Esquire advised Action Management, Inc. that his office provided a final accounting to their attention on January 17, 2000 and that Action Management, Inc. now has all original files that had been in the possession of Daniel F. Wolfson, Esquire and Wolfson & Associates, P.C. (Please see attached marked Exhibit "A") 6. As of the filing of this Motion, Daniel F. Wolfson, Esquire and the law firm of Wolfson & Associates, P.C. has not entered their withdrawal of appearance. 7. Due to the flagrant mishandling of the cases assigned to Daniel F. Wolfson, Esquire and the law firm of Wolfson & Associates, a severe break down in communications has occurred between the two (2) parties. Therefore, the Plaintiff, Action Management, Inc., is requesting that Daniel F. Wolfson, Esquire and the law firm of Wolfson & Associates, P.C. be ordered to withdrawal their appearance as counsel in the above captioned matter. WHEREFORE, Harry A. Strausser, Jr., President and CEO of Plaintiff, Action Management, Inc., prays that this Honorable Court grants the request of the foregoing Motion to Remove Daniel F. Wolfson, Esquire and the law firm of Wolfson & Associates, P.C. in the above captioned action. Respectfully submitted: Al Ct. HARRY TRAUSSER, JR. President and CEO Action Management, Inc. P O Box 276 58 West Valley Avenue Elysburg PA 17824 (570) 672-9732 IF ATfORNEYS Daniel F. Wolfson ,.Michael J. Connor Gerard J. rnulke COl1NSEL Morrison B. Williarns Jodi Trout Bingaman PARALEGALS Angela S. Kiton Margaret L. Burg Susan K. Kostalas 7 February 2000 WOLFSON & ASSOCIATES, P.G. Attorneys at Draw .. BRANCH OFPICES: 'Center square 267 East Market Street East Berlin, PA 17316 York, Pennsylvania 17403 (717)2590713 ---------- 8 Manchester Street (717) 846-1252 Glen Rock, PA 17327 (800) 321-8467 (717) 235.5014 . FAX (717) 8418-1146 PLEASE FORWARD ALL CORRESPONDENCE TO -•• ------ T11E YORK OFFICE c-nsril: d6•:01f5on(?i debtcollection.neI SENT VIA FACSIMILE AND REGULAR MAIL Action Management, Inc. Harry Strausser P.O. Box 276 Elysburg, PA 17824 RE: Yours titled "FILES UNDER YOUR CONTROL" Dear Mr. Strausser: Enclosed please find a statement of account for AMI v. Andrus. This is the ONLY outstanding account that required an accounting. On January 17, 2000, my office forwarded a final accounting to your attention. You now have every original file under your control as well as a final accounting of every file that was ever in our possession. As you know, there are numerous files which required Motions to Withdraw: We do not intend to incur any additional court costs on these accounts pending the finalization of the motions. Please direct any questions or concerns to me in writing. Thank you for your continued cooperation. Very truly yours, WOLFSON 8s ASSOCIATES, P.C. ?Danti FWolfsW/afw 9 rro 1(0, 3jG I 3Ll0 U!` r ?I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION MANAGEMENT, INC., NO: 99-6829 Plaintiff CIVIL ACTION - LAW VS. District Justice Charles A. Clement, Jr. DAVID D. DEETZ, SR. District Ct No: 09-1-01 Defendant CV #294-98 AFFIDAVIT I, HARRY A. STRAUSSER, JR., President and CEO of Action Management, Inc., do hereby swear and affirm that all the facts contained in the foregoing Motion are true and correct to the best of my knowledge, information and belief. I further aver that this Motion is not interposed for the purpose of delay. SWORN and SUBSCRIBED before me this day of? ^?ut. , ? 2000. ARY PUBLIC NOTARM SEAL PAULA A STRO4, Nctoy Pubr' Rctp Twp„ Northvmbwlond County my Commlukn EWrer Feb. 1, 20C7 HARRY TRAUSSER,JR. President and CEO Action Management, Inc. P 0 Box 276 58 West Valley Avenue Elysburg PA 17824 (570) 672-9732 _A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION MANAGEMENT, INC., Plaintiff REGULAR MAIL-POSTAGE PREPAID CIVIL ACTION - LAW VS. DAVID D. DEETZ, SR. Defendant NO: 99-6829 District Justice Charles A. Clement, Jr. District Ct No: 09-1-01 CV #294.98 CERTIFICATE OF SERVICE AND NOW, this day of/A A12 , 2000, I, HARRY A. STRAUSSER, JR., President and CEO of Action Management, Inc., do hereby certify that I have served a copy of the foregoing Motion to Remove as Counsel upon the parties and counsel of record in the following manner and addressed as follows: CERTIFIED MAIL RETURN RECEIPT REQUESTED and REGULAR MAIL - POSTAGE PREPAID DANIEL F. WOLFSON, Esquire Wolfson & Associates, P.C. 267 East Market Street York PA 17403 (Plaintiffs Counsel of Record) DAVID D. DEETZ, SR. 204 Produce Road RR#3 Selinsgrove PA 17870 (Defendant) HARRY . TRAUSSER, JR. President and CEO Action Management, Inc. P O Box 276 58 West Valley Avenue Elysburg PA 17824 (570) 672-9732 O1 !1-? ` > 1 CL. f !o J W ._ ` I % V- ?? ? 111I1? 11. O U CD