HomeMy WebLinkAbout07-5636
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD MOTOR CREDIT COMPANY, )
PRIMUS FINANCIAL AUTOMOTIVE )
SERVICES )
Plaintiff, )
V. )
DANIEL LONGWELL AND )
JANE DOE LONGWELL, )
Defendant. )
NO. b7 - 5(c3(o (iiv t t ~CfM
PRAECIPE FOR
APPEARANCE,
TRANSFER OF
JUDGMENT,
ASSESSMENT OF
DAMAGES AND
VERIFICATION OF
ADDRESS, VALIDITY
AND NONMILITARY
SERVICE AGAINST
DANIEL LONGWELL
ONLY
I hereby certify that the true
and correct address of Plaintiff is:
C/O Patenaude & Felix, A.P.C.
Plaintiff
213 E. Main Street
Carnegie, PA 15106
and that the last known address of
Defendant(s) is:
6002 ROBERT DR
MECHANICSBURG, PA 17050
The Law Offices of Patenaude & Felix, A.P.C.
Filed on behalf of
Ford Motor Credit Co.
Primus Financial Automotive
Services
Counsel of Record for This
Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
Esquire
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD MOTOR CREDIT COMPANY, )
PRIMUS FINANCIAL AUTOMOTIVE ) NO.
SERVICES )
Plaintiff, )
V. )
DANIEL LONGWELL AND )
JANE DOE LONGWELL, )
Defendant. )
PRAECIPE FOR APPEARANCE, TRANSFER OF JUDGMENT, ASSESSMENT OF
DAMAGES AND VERIFICATION OF ADDRESS, VALIDITY AND NONMILITARY
SERVICE AGAINST DANIEL LONGWELL ONLY.
TO: PROTHONOTARY
Please enter my appearance for the Plaintiff in the above matter; enter judgment in favor of
Plaintiff against Defendant(s) on the duly authenticated copy of the judgment contained in the
docket entries hereto attached, entered in the jurisdiction noted therein, and assess damages as
follows:
Judgment Due $ 7,582.08
Interest $ 1,212.25
Costs 249.50
TOTAL $ 9,043.83
With continuing interest on the principal amount of $ 9,043.83, plus costs.
Pursuant to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to
authorities, I hereby verify that: (1) the precise last known address of the Plaintiff and
Defendant(s) are as above; (2) that said judgments were entered in the said jurisdiction in said
amount with costs and interest due as noted, no part of which has been paid (except as noted) and
which is valid, enforceable and unsatisfied; (3) and that Defendant(s) is (are) over 18 years of age
and not in the military service of the United States of America or its allies or otherwise within
coverage of the Soldiers and Sailors Relief Act of 1940, as amended, and has (have) civilian
occupation(s) to the best of his knowledge, information and belie
& Felix, A.P.C.
Sworn to and subscribed before me
this ~ day of .J J~~ 2007, By:
~ ~. 7
Notary Public
~~ NOtia21At SEAL w
-Et21N N BALTZELL
Notary Pudic
CAkNEGIE BOROUGH, ALLEGHENY CO
My Commission Expires Jul 21, 201
Gregg L. Morris, Esquire
Patenaude & Felix, A.P.C
21 E. Main Street
Pit burgh, PA 15106
~l 1429-7675
In the Superior Court of the State of Washington,
,~ , " In and for Snohomish County. ,
I~'MC DBA PRIM[IS FINANCIAL SERVICES
Plaintiff/Petitioner ` p I
V. Case/Cause No. ~ - 2â - ~ 7 D q '
DANIEL LONGWELL AND JANE DOE LONGWELL Certificate
Defendant/Respondent
I, Pam L. Daniels, County Clerk and ex Officio Clerk of the Superior Court of the State of Washington, in and for Snohomish
County, do hereby certify that the foregoing is/are a true and correct copy(ies) of:
as the same now appears in my office.
IN WITNESS WHEREOF, I
By:
gave hereunto set my hand and fixed the seal of said
at Sno mish, thi~ d _ 20 D(p
Clerk ancj,@x Offio clerk of said Superior Court
Deputy
STATE OF WASHINGTON
ss Judges Certificate
Snohomish County
I, GEORGE N : BOWDEN ,Judge of the Superior Court of the State of Washington, for
Snohomish County, do hereby certify that Pam L. Daniels, whose signature is attached to the above and foregoing Certificate,
now is, and was at the signing and sealing of said Certificate, the duly elected, qualified and acting County Clerk, and ex
Officio Clerk of said Superior Court, and the person having by law the custody of the Seal of said Court; that said certificate is
in due form, and that said Clerk's signature thereto is genuine, and that the above seal impress is the genuine impress of said
seal.
Witness my hand and the seal of said Superior Ccurt hereto affixed
this
1 day of~_ 20 a
Judge oft a said erior ourt
STATE OF WASHINGTON
ss Clerk's Certificate
Snohomish County
I, Pam L. Daniels, County Clerk, and ex Officio Clerk of the Superior Court of the State of Washington, in and for
Snohomsh County, said State, do hereby certify that Hon. GEORGE N. BOWDEN
whose signature is affixed to the above and foregoing Certificate, now is, and was at the signing, the duly elected, qualified and
acting Judge of the Superior Court of the State of Washington, in and for Snohomish County, said State, and that his/her said
signature is genuine.
Witn ss my hand n~he seal of said . erior C rt hereto affixed this
Clerk of the said Su'p~erior Court
,~.
~~ _ _.
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i~~'r nr~'rr
~,eo~e,
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205 SEA 28 APi 9~ :~ S
.JE,i:l~i,:i
%;3UiJ ~ Y Ci_ERK
aNOHOMiSN CO. YIASN.
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
FOR SNOHOMISH COUNTY r-~
FMC d/b/a PRIMUS FINANCIAL SERVICES ~ ~~ ~ ~ ~ `
Plaintiff, ~ No.
vs. ~ ORDER OF DEFAULT
AND DEFAULT
DANIEL LONGWELL and JANE DOE ~ JUDGMENT
LONGWELL, husband and wife, and their marital ~
community composed thereof, ; (Clerk's Action Required]
Defendants.
JUDGMENT SUMMARY
Judgment Creditor: FMC d/b/a PRIMUS FINANCIAL SERVICES
Attorney for Judgment Krista L. White, Patrick J Layman
Creditor: BISHOP, WHITE & MARSHALL, P.S.
Judgment Debtors: DANIEL LONGWELL and JANE DOE
LONGWELL .w/t/n/i TARA LONGWELL and
their. marital community
Principal Amount:
Interest to Date of Judgment:
Taxable Costs:
Filing Fee:
Service of Process:
TOTAL JUDGMENT:
ORIGINAL
~~ ORDER OF DEFAULT AND DEFAULT JUDGHENT - 1
$7,582.08
$1,212.25
$200.00
$49.50
$9,043.83
BISHOP, WHITE & MARSHALL, P.S.
PO Hox 2186
5eaale, Washington 98111-2186
720 olive way, suiu 130!
seaale, Washington 9910!
206/622-5306 Fax: 206/622-0354
877/259-1016
1
~1~. - .
Past Judgment interest accrues at the rate of 23.25% per annum on the total
judgment.
II. ORDER AND JUDGMENT
Plaintiffs motion for an order of default and default judgment against the
above named defendants came on for hearing on this date before the undersigned
judge/court commissioner of this court. The court, having found that: (1) the
defendants were duly served with a summons and complaint and have failed to
appear, answer, or otherwise defend within the time provided by law; (2) finds that
the venue is proper; and {3) the defendants are justly indebted to the plaintiff, as
evidenced by the proof presented herewith, now, therefore, it is hereby
ORDERED, ADJUDGED and DECREED that the defendants are in default.
It is further
ORDERED, ADJUDGED and DECREED that plaintiff have and is hereby
granted judgment against defendants, DANIEL LONGWELL and JANE DOE
LONGWELL w/t/n/i TARA LONGWELL and their marital community, jointly and
severally, in the principle amount of $7,582.08, plus interest of $1,212.25, court costs
and disbursements totaling $249.50, for a total judgment of $9,(}43.83.
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~~ ORDER OF DEFAULT AND DEFAULT JUDGMFN'C - 2
BISHOP, WHITE & MARSHALL, P.S.
1'0 Box 2186
Scattlt:, Washington 98111-2186
720 Olive Way, Suite 1301
Seattle. Washington 98101
206/622-5306 Fax; 206/622-0354
877lZ59-1016
"Y
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~' Postjudgment interest shall accrue on the judgment total at the rate of at 23.25% per
annum.
DONE IN OPEN COURT this day o$EP 2 8 ZD~3 2005.
~ ~~~~~
J E/C URT COMMISSIONER
Presented by:
BISHOP, WHITE & MARSHALL, P.S.
~c~
Patrick J. La SB# 5707
Krista L. White WSB# 8612
Attorney's for Plaintiff
1 ORDER OF DEFAULT AND DEFAULT JUDGMENT - 3
BISHOP, WHITE & MARSHALL, P.S.
PO Box 2186
Seattle, Washington 981! 1-218fi
720 Olive Way. Suiu 1301
Seattle. Washington 98101
2061622-5306 Fax: 206/622-0334
877/259-1016
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD MOTOR CREDIT COMPANY, )
PRIMUS FINANCIAL AUTOMOTNE ) NO.
SERVICES )
Plaintiff, )
V. )
DANIEL LONGWELL AND )
JANE DOE LONGWELL, )
Defendant. )
NOTICE OF ORDER,
DECREE OR JUDGMENT
Filed on behalf of
Ford Motor Credit Co. Primus
Financial Automotive
Services,
Plaintiff
Counsel of Record for This
Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Pittsburgh, PA 15106
(412) 429-7675
⢠" r ~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD MOTOR CREDIT COMPANY, )
PRIMUS FINANCIAL AUTOMOTIVE ) NO.
SERVICES )
Plaintiff, )
V. )
DANIEL LONGWELL AND )
JANE DOE LONGWELL, )
Defendant. )
NOTICE OF ORDER. DECREE OR JUDGMENT
TO: ( )Plaintiff (x )Defendant ( )Garnishee ( )Additional Defendant
You are hereb notified that the following Order, Decree, or Judgment has been entered
against you on oZ ~ b'~
Decree Nisi in Equity
Final Decree in Equity
Judgment of ( )Confession ( )Verdict ( )Court Order
( )Default ( )Non-suit
( )Non-Pros ( )Arbitration Award
(X) Judgment in the amount of 9 043.83, plus costs.
( )District Justice Transcript of Judgment in the amount of $ ,
plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be
suspended by the Department of Transportation.
Prothonotary
By S ~G~I.S
If you have questions concerning the above, please contact:
Name of Attorney: Gregg L. Morris Esquire
213 E. Main Street
Pittsburgh PA 15106
X412) 429-7675
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FILED-OFFICE
a . 'fHE PROTHONOTARY
201 i JUi 24 PM 1:39
rU PENNSYLVANIA COUNTY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD MOTOR CREDIT COMPANY,
PRIMUS FINANCIAL AUTOMOTIVE SERVICES
Plaintiff
V.
DANIEL LONGWELL AND
JANE DOES LONGWELL,
Defendant(s)
NO. 07-5636
)
PRAECIPE FOR
SATISFACTION OF
JUDGMENT
Filed on behalf of:
PRIMUS FINANCIAL
AUTOMOTIVE SERVICES
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA-147 Prcp Sat Jg
P& I File No. 2800.5089
f
1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
FORD MOTOR CREDIT COMPANY,
PRIMUS FINANCIAL AUTOMOTIVE SERVICES
Plaintiff
NO. 07-5636
V.
DANIEL LONGWELL AND
JANE DOE LONGWELL
Defendant(s)
PRAECIPE TO SATISFY JUDGMENT
TO: PROTHONOTARY
Please satisfy the Judgment at the above captioned action of record upon payment of your
costs, only. Thank you.
Respectfull
A.P.C.
Date. June 14, 2011
uire
PA-147 Prcp Sat Jg
7arnegie,AM 15106
(412) 429-7675
P&I File No. 2800.5089
41
I, GREGG MORRIS, attorney for Plaintiff, PRl MUS FINANCIAL AUTOMOTIVE
SERVICES , hereby certify that a true and correct copy of foregoing document was served this
date by ordinary mail upon the following:
DANIEL LONGWELL
200 LIPPERT DR WESTAPT G137
PORT ORCHARD WA 98366
Date: June 14, 2011
PA-147 Prcp Sat Jg
P&I' File No. 2800.5089
Carnegie, PA 15106
(412) 429-7675